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of <h1>Article 11 of DTAA: Interest Taxed at Max 10% for Beneficial Owners, Exemptions for Government Entities and Banks</h1> Article 11 of the Double Taxation Avoidance Agreement (DTAA) between South Africa and another Contracting State addresses the taxation of interest. Interest paid to a resident of the other Contracting State may be taxed there, but also in the State where it arises, with a maximum tax rate of 10% if the recipient is the beneficial owner. Exemptions apply for interest beneficially owned by government entities, central banks, or approved agencies. 'Interest' includes income from debt-claims, securities, bonds, or debentures, excluding penalty charges. Exceptions exist for business activities connected to a permanent establishment. Special relationships affecting interest amounts are subject to standard taxation rules.
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