Guide to investing in South Africa
The new dividend withholding tax is levied at a rate of 15% on dividends declared by domestic companies and shares of non-resident companies that are listed on the JSE. (The 15% rate may be reduced under an appropriate double tax agreement).

Dividend payments to the Government, and various other bodies (defined in the act) will be exempt, and foreign persons will be eligible for tax treaty relief. Exempt shareholders will have to certify their exemption status.

In respect of in-specie dividends, the distributing company (not the shareholder) will bear the liability, although it will be subject to similar exemptions and treaty relief as cash dividends. The major implication is likely to be administrative.

The “dividend” definition has been broadened, which essentially means that value-transfers (understood as “deemed dividends”) may still be taxed.

A dividend will be deemed to be paid on the earlier of the date on which the dividend is paid or becomes payable by the company that declared the dividend.