RETAINED RECORD: NON-OPERATIVE / NOT IN FORCE · NICHT IN KRAFT · 2008 source edition
Source edition / Quellenfassung

Interface language: English. Document language: English (EN).

de-south-africa-2008-not-in-force · EN

Article 21 Capital

2024 protocol not incorporatedUnreviewed · applicability unverified

All 30 articles

Source paragraph 1

(1) Capital represented by immovable property‚ owned by a resident of a Contracting State and situated in the other Contracting State‚ may be taxed in that other State.

Source paragraph 2

(2) Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State may be taxed in that other State.

Source paragraph 3

(3) Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic‚ and by movable property pertaining to the operation of such ships and aircraft‚ shall be taxable only in that State.

Source paragraph 4

(4) All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

Disclaimers

Unreviewed source publication; current applicability has not been verified.

Local NOINDEX review only. Excluded from current/comprehensive counts. Noindex is not access control. Parent independently decides any source-edition listing or deployment after review and release gates.

Embedded data, audit, scope evidence and sealed input build manifest are immutable input records, NOT mounted output hashes or publication approval. Mount output hashes and transformations are sealed by the enclosing release. Separate non-operative source publication only.

Source-page links are references, not human paragraph verification.