To learn how to borrow books from the library, check out our guide to lending books. You will receive copies of articles or extracts from books and reports by post, fax or e-mail via our document delivery service. Determining the position of the person`s “contractual residence” is essential to determine whether it is possible to do so and how to apply a double taxation treaty, given that this is the country of contractual residence that generally assumes the taxing rights. 4. This Convention shall also apply to all identical or substantially similar fees levied by one of the States Parties after the date of signature of this Convention, in addition to or in place of existing fees. The competent authorities of the States Parties shall inform each other of any substantial changes to their respective tax legislation. It is much more common to use the services of a qualified accountant who is experienced in applying for tax relief through double taxation treaties. Fees vary depending on the complexity of a person`s personal circumstances, in almost all cases, tax savings exceed the costs of using an accountant – and they can be sure to pay the right amount of tax with absolute confidence. 1. The competent authorities of the Contracting States shall exchange information necessary for the application of the provisions of this Convention or of the domestic law of the Contracting States concerning the taxes covered by this Convention, in so far as the taxation of this Convention does not preclude the prevention of fraud and to facilitate the management of anti-risk legislation.
Article 1 of the Convention does not restrict the exchange of information. All information received by a Contracting State shall be treated as confidential and shall be communicated only to persons or authorities (including courts and administrative authorities) responsible for the assessment, investigation, enforcement or prosecution or decision of appeals in respect of taxes covered by this Convention. Such persons or authorities may only use this information for that purpose. You may disclose the information as part of a public legal proceeding or court order. 4. The competent authorities of the Contracting States may communicate directly with each other with a view to reaching an agreement within the meaning of the preceding paragraphs. If the foregoing proposal is acceptable to the Government of the Republic of South Africa, I have the honour to suggest that this note and Your Excellency`s reply should be regarded as an agreement between the two Governments on the matter, which shall enter into force at the same time as the entry into force of the Convention. 1.
If a State established in a Contracting State considers that the conduct of one or both Contracting States will result in or will result in taxation for that person which is not in conformity with the provisions of this Convention, that person may, irrespective of the remedies provided for by the domestic law of those States, be subject to the competent authority of the Contracting State in which the person is established: present a case or, if the case falls within the scope of article 23, paragraph 1, of this Convention, in the case of the State Party of which the person is a national. . . .