On October 6, 2017 the South African Revenue Service (SARS) announced that the Agreement between the Government of the Republic of South Africa and the Government of the Oriental Republic of Uruguay for the Exchange of Information relating to Tax Matters, as signed on August 7, 2015 (Hereafter: the TIEA) entered into force on October 6, 2017.

Based on Article 3, Paragraph 1 of the TIEA (“TAXES COVERED”) the TIEA shall apply to the following taxes imposed by the Parties:

(a)  in the case of Uruguay, all taxes imposed or administered by the Government of Uruguay; and

(b)  in the case of South Africa:

(i)   the normal tax;

(ii)  the withholding tax on royalties;

(iii) the dividend tax;

(iv) the withholding tax on interest;

(v)  the tax on foreign entertainers and sportspersons; and

(vi) the value-added tax.

Article 3, Paragraph 2 subsequently arranges that the TIEA shall apply also to any identical taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes, or any substantially similar taxes if the Parties so agree.

Based on Article 12 of the TIEA (“ENTRY INTO FORCE”) the fact that the TIEA entered into force on October 6, 2017 means that the provisions of the TIEA shall have effect:

(a)  for criminal tax matters on October 6, 2017; and

(b)  for all other matters covered in Article 1 on October 6. 2017, but only in respect of taxable periods beginning on or after October 6, 2017 or, where there is no taxable period, all charges to tax arising on or after October 6, 2017.

The TIEA arranges a.o. for the exchange of information upon request (Article 5) and the possibility to conduct tax examinations abroad (Article 6).

Click here to be forwarded to the text of the TIEA as available on the website of the South African Revenue Service, which will open in a new window.

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