Interface language: English. Document language: English (EN).
de-south-africa-2008-not-in-force · EN
Article 21
Capital 2024 protocol not incorporated Unreviewed · applicability unverified Print / Drucken
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.
Article 20
Other Income Article 22
Elimination of Double Taxation 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.
Original, non-operative source publication · NOT IN FORCE / NICHT IN KRAFT Signed Berlin, 9 September 2008. Unreviewed machine transcription, not legal advice, current law or a complete current treaty chain. No human wording, alignment or publication approval.
The cached BMF article states “noch nicht in Kraft getreten” for both the 2008 agreement and the separate 6 March 2024 protocol. This is a retained observation, not fresh currentness proof. The 2024 protocol is NOT incorporated or acquired. Only the integral 2008 protocol is included.
German and English are equally authentic according to the source closing clauses. This reader makes no approved cross-language alignment claim. Entry/termination language below is source wording, not evidence of operation.
EN original PDF · Both source hashes and provenance · Complete 2008 source supplements
Source-page links are references, not human paragraph verification.