A Protocol to the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, with Protocol, will be signed in Pretoria by the Deputy Minister of Finance, Ms Gill Marcus and the Ambassador Extraordinary and Plenipotentiary of the Kingdom of the Netherlands, Mr Herman R R V Froger.
The Protocol introduces amendments to the Convention which became necessary when the Netherlands introduced an amendment to their national fiscal legislation in terms of which non-residents of the Netherlands will no longer be taxable in the Netherlands on income from debt-claims secured by mortgage on immovable property situated or established there. The right to tax such income was previously contained in paragraph 2 of Article 6 of the Convention. In order to now deal with this income on the same basis as all other interest income, the above-mentioned paragraph has been amended with a consequential amendment to paragraph 3 of Article 11 which deals with interest in general.
The signing will take place at the office of the Deputy Minister of Finance, Ms Gill Marcus at 10:45 on 15 December 1998, at 240 Vermeulen Street Pretoria.
ISSUED BY THE COMMISSIONER FOR THE SOUTH AFRICAN REVENUE SERVICE
Ron van der Merwe
Tel No: (012) 422-5144
Fax No: (012) 422-5191