A PROTOCOL to the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income, was recently signed in Pretoria by the Deputy Minister of Finance, Gill Marcus and the Ambassador Extraordinary and Plenipotentiary of the Kingdom of The Netherlands, Herman R R V Froger.
The protocol introduces amendments to the convention which became necessary when The Netherlands introduced an amendment to its national fiscal legislation in terms of which non-residents of The Netherlands would 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 the convention.
To deal with this income on the same basis as
all other interest income, the convention has been amended to deal with interest in general.
BY ANNA COX
