Notes: 1.
No withholding tax if the royalty is subject to tax in the recipient’s country of residence.
2.
Rate reduced to 6% in respect of copyright royalties and other like payments in respect of any literary, dramatic, musical or other artistic work or royalties for use of computer software, or for use of any patent or any industrial, commercial or scientific information. Reduced rates do not apply to royalties in respect of films or videos or other means of reproduction for use in television broadcasting, nor does it apply to information in connection with rental/franchise agreements.
3.
As per note (1) with the exception of the use of cinematograph or television film where withholding tax of 15% of the company tax (ie: 5.25%) applies.
4.
The treaty provides that the rate may not exceed 15%.
5.
Withholding tax on the payments for the use of, or right of use, any industrial, commercial or scientific equipment, should be raised on 70% of the gross value of the payments.
6.
5% of the gross amount of the payments of any kind received to the use of, or right to use, any copyright or literary, artistic or scientific work including cinematograph films and films, tapes or disc or any other media for television or radio broadcasting, and 7% of the use of, or the right to use, any patent, trademark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific experience.
7.
If paid for the use of, or the right to use, industrial, commercial or scientific equipment, or transport vehicles. 10% in all other cases.
8.
In respect of the copyright royalties and other similar payments in respect of the production or reproduction or any cultural, dramatic, musical or other artistic work (but not including royalties in respect of motion picture films and works on film or videotape or other means of reproduction for use in connection with television) and royalties paid for the use of industrial, commercial or scientific equipment. 10% in all other cases.
9.
15% of the gross amount is paid for the use of, or the right to use trademarks. 10% on all other leases.
10. With the exception of Austria, Canada, Croatia, Czech Republic, Denmark, Finland, Greece, India, Ireland, Japan, Korea, Malta, Norway, Seychelles, Singapore, Sweden, UK and USA, there is no relief granted for STC. 11. Limited sea and air transport agreements are in force with Portugal and Spain.
PKF - Doing business in South Africa Supplementary information 67