How are pensions taxed under the United States-South Africa tax treaty?

The United States-South Africa tax treaty sets the withholding rate on pensions at 15%. This means the country paying the pension may withhold up to 15% at source. The recipient's country of residence will typically provide a credit or exemption for this withholding to avoid double taxation. Social security benefits are subject to a separate rate of 30% under this treaty. This 15% rate compares to a median of 0% across United States's 64 active treaty partners, and 0% across South Africa's 37 active partners.