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Double Taxation Agreements and Cross Border Withholding Tax

South African companies paying dividends, interest, royalties or service fees across borders often apply withholding tax incorrectly because they misread a double taxation agreement or miss a required declaration. This course explains how double taxation agreements interact with domestic withholding tax rules, how to apply reduced rates correctly, and how to handle beneficial ownership and treaty shopping challenges.

What you will be able to do

  • Explain how double taxation agreements reduce or eliminate withholding tax obligations.
  • Apply the correct withholding tax rate on dividends, interest, royalties and service fees.
  • Complete the declarations required to apply a reduced treaty rate.
  • Assess beneficial ownership requirements when applying treaty relief.
  • Identify treaty shopping arrangements that SARS is likely to challenge.
  • Reconcile withholding tax obligations with foreign tax credit relief for South African taxpayers.

Course outline

  1. 01How double taxation agreements work
  2. 02Withholding tax on dividends and interest
  3. 03Withholding tax on royalties and service fees
  4. 04Treaty relief declarations and documentation
  5. 05Beneficial ownership requirements
  6. 06Treaty shopping and anti avoidance
  7. 07Foreign tax credits for South African taxpayers
  8. 08Common cross border withholding errors

Who should attend

Tax managers, financial controllers, treasury staff and accountants handling cross border payments and withholding tax compliance.

Dates, venues and fees

DatesVenueDaysFeeCalendar
17 to 18 Aug 2026Cape Town2R10,000
31 Aug to 1 Sep 2026Online2US$900
7 to 8 Sep 2026Mozambique2US$1,100
14 to 15 Sep 2026Cairo2US$1,100
21 to 22 Sep 2026Accra2US$1,100
28 to 29 Sep 2026Lusaka2US$1,100
5 to 6 Oct 2026Kigali2US$1,100
12 to 13 Oct 2026Nairobi2US$1,100
19 to 20 Oct 2026Durban2R10,000
26 to 27 Oct 2026Johannesburg2R10,000
9 to 10 Nov 2026Mauritius2US$1,100
16 to 17 Nov 2026Dubai2US$1,100
23 to 24 Nov 2026Lagos2US$1,100
30 Nov to 1 Dec 2026Harare2US$1,100
7 to 8 Dec 2026Kampala2US$1,100
14 to 15 Dec 2026Dar es Salaam2US$1,100
21 to 22 Dec 2026Pretoria2R10,000

Fees are per delegate. South African venues are priced in rand; other locations and online in US dollars. Fees exclude 15% VAT where applicable. Group bookings of three or more delegates from the same organisation qualify for a reduced rate; contact us for a quotation.

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