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Ratification of tax treaty between South Africa and Kenya

25 November 2014   (0 Comments)
Posted by: Author: PwC South Africa
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Author: PwC South Africa

The Tax Treaty between Kenya and South Africa was concluded in 2010 and ratified by South Africa in 2011. Kenya ratified the treaty in October 2014. South Africa is awaiting official diplomatic notification before the treaty comes into effect

The treaty represents a significant development between two of the economic powerhouses in Africa. South Africa represents the largest African investor in Kenya and this treaty also promotes South Africa as a possible intermediate holding company location for investments into Kenya. We highlight some of the notable clauses in the treaty.

Summary of withholding tax rates

We provide below a summary of the domestic withholding tax rates and the reduced rates under the treaty.

Please click here to view. 

This article first appeared on



Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.


The Act requires that a minimum academic and practical requirments be set to register with a controlling body. Click here for the minimum requirements of SAIT.

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