RE: Dividends6 Feb 2022 15:40
Heretical suggestion, but I think the full stop should be a comma and the "F", uncapitalised, there should be only "two", sentences, not "three". This is one of the reasons I was flummoxed months/weeks ago when mentioning SA Witholding Tax. It's a typo.
"In the case of UK resident Shareholders, the convention between the UK and South Africa for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains, concluded on 4 July 2002, as amended by a protocol signed on 8 November 2010 (the “UK/South Africa Treaty“) provides for lower withholding rates of 5%. If the Shareholder is a company which holds at least 10% of the capital of the Company or 10%, in other cases. In order to benefit from a lower withholding tax rate under the terms of the UK/South Africa Treaty, the UK resident Shareholder would be required to lodge the prescribed declaration and written undertaking with the Company prior to any distribution or such other date as the Company may announce."