Double Taxation Agreement South Africa and Sweden

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Double Taxation Agreement South Africa and Sweden

Double Taxation Agreement between South Africa and Sweden: A Brief Overview

South Africa and Sweden are two countries that maintain extensive economic and political relations. Given their significant trading, investment, and other forms of transactions, the two countries had to address the issue of double taxation. Double taxation arises when two countries impose taxes on the same income or capital, which can result in a significant economic burden on taxpayers. To avoid this situation, South Africa and Sweden have signed a double taxation agreement (DTA), which outlines the rules for taxation applicable to the income or capital of taxpayers in the respective countries.

What is a DTA?

A DTA is an agreement between two or more countries to avoid double taxation and prevent fiscal evasion. It provides clarity on the tax obligations of taxpayers who conduct business or earn income in other countries. Most DTAs have similar provisions, such as:

– Definition of key terms

– Guidelines for determining the tax residency of individuals and businesses

– Rules for avoiding double taxation

– Provisions for resolving disputes between the countries

What are the provisions of the DTA between South Africa and Sweden?

The DTA between South Africa and Sweden was signed in Pretoria, South Africa on 27 October 1995. It entered into force on 1 July 1996 and has since been amended in 2006. The agreement covers various forms of taxes, including income tax, capital gains tax, and withholding taxes.

Residency: The DTA outlines the criteria for determining the residency of individuals and businesses. As per the agreement, a resident of a contracting state is subject to taxation in that state on their worldwide income. The term “resident” is defined to include any person or entity that is liable to tax in that state.

Business profits: The DTA provides guidelines for taxation of business profits. In general, the country where the business operates has the right to tax its profits. However, if the enterprise operates in the other country through a permanent establishment (PE), then the profits attributed to the PE are taxable in that country. The DTA provides a definition of a PE and outlines the rules for calculating its profits.

Dividends, interest, and royalties: The DTA provides relief from double taxation on dividends, interest, and royalties. The rates of withholding tax applicable to these payments are lower than the domestic rates. For instance, the withholding tax on dividends is 5% if the recipient is a company resident in the other country that owns at least 10% of the voting power of the dividend-paying company. The withholding tax on interest and royalties is 10%.

Capital gains: The DTA provides rules for determining the taxation of capital gains. Generally, gains from the sale of immovable property are taxed in the country where the property is located. Gains from the sale of other assets are taxable in the country where the seller is resident, except in certain circumstances. For instance, gains from the sale of shares in a company whose assets consist primarily of immovable property are taxable in the country where the immovable property is located.


The DTA between South Africa and Sweden provides certainty and clarity to taxpayers who conduct business or earn income in the other country. By avoiding double taxation and preventing fiscal evasion, the DTA helps promote trade, investment, and economic cooperation between the two countries. As an experienced copy editor in SEO, it`s important to understand the basics of DTAs and their implications for international business.