(2) The Agreement shall enter into force on the day of the exchange of the instruments of
ratification and shall have effect in both Contracting States:
a) in the case of taxes withheld at source‚ in respect of amounts paid or credited on
or after the first day of January of the calendar year next following that in which
this Agreement entered into force;
b) in the case of other taxes‚ in respect of taxes levied for periods beginning on or
after the first day of January of the calendar year next following that in which
this Agreement entered into force.
(3) Upon the entry into force of this Agreement the Agreement between the Federal
Republic of Germany and the Republic of South Africa for the Avoidance of Double
Taxation with Respect to Taxes on Income signed on 25th January 1973 shall expire and
shall cease to have effect for any period for which the provisions of this Agreement have
effect.