(1) This Agreement shall apply to taxes on income and on capital imposed on behalf of a
Contracting State‚ of a Land or a political subdivision or local authority thereof‚
irrespective of the manner in which they are levied.
(2) There shall be regarded as taxes on income and on capital all taxes imposed on total
income‚ on total capital, or on elements of income or of capital‚ including taxes on gains
from the alienation of movable or immovable property‚ taxes on the total amounts of
wages or salaries paid by enterprises‚ as well as taxes on capital appreciation.
(3) The existing taxes to which this Agreement shall apply are in particular:
a)
in the Federal Republic of Germany:
i. the income tax (Einkommensteuer);
ii. the corporation tax (Körperschaftsteuer);
iii. the capital tax (Vermögensteuer); and
iv. the trade tax (Gewerbesteuer);
including the supplements levied thereon;
(hereinafter referred to as ”German tax”);
b)
in South Africa:
i. the normal tax;
ii. the secondary tax on companies; and
iii. the withholding tax on royalties;
(hereinafter referred to as ”South African tax”).
(4) This Agreement shall apply also to any identical or substantially similar taxes that are
imposed after the date of signature of this Agreement in addition to‚ or in place of‚ the
existing taxes. The competent authorities of the Contracting States shall - if necessary for
the application of this Agreement - notify each other of changes that have been made in
their respective taxation laws.