Global Daily Tax News, South Africa Explains BEPS Changes To Six DTAs, (Apr 28, 2026)
The South African Revenue Service has issued new synthesized texts of the nation's double tax agreements with six nations, as modified by the BEPS multilateral instrument (BEPS MLI).
The new treaty texts are for the nation's double tax agreements with Denmark, Indonesia, Israel, Kenya, Malta, and Portugal.
The texts are intended to provide guidance to taxpayers and their agents regarding the scope of the changes, which center on countering treaty abuse, preventing the artificial avoidance of permanent establishment status, and neutralizing the effects of hybrid mismatch arrangements.
Provisions are also added to improve how double tax treaty interpretation disputes are resolved.