Italy – South Africa Tax Treaty
The Italy-South Africa tax treaty caps withholding on dividends at 15% for portfolio investors and 5% for qualifying direct investment, and interest at 10%. Royalties are taxed at a uniform 6% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 47 active treaties in Italy's network and one of 37 in South Africa's. The general dividend rate of 15% compares to a median of 15% across Italy's network and 15% across South Africa's.
Verified data
South African Revenue Service (sars.gov.za) - Double Taxation Agreements (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12). South Africa levies 20% dividend WHT, 0% on interest to non-residents (but 15% WHT on interest was introduced in 2015 via s.50E ITA; now typically 0% domestic exemption applies to most treaty states), 15% on royalties.)
Withholding Rate Summary
Source: South Africa Treaty Reference| Income Type | Treaty Rate | Statutory Rate (South Africa) |
|---|---|---|
| Dividends (general) Portfolio investors | 15%saves 5% | 20% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 15% | 20% |
| Interest Bank interest, bonds, loans | 10% | 0% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 6% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (South Africa)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 15% applies to portfolio investors. A reduced rate of 5% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 20%.
Source: South Africa Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 10% withholding under this treaty, compared to the 0% statutory rate. This represents a no reduction from the statutory rate.
Source: South Africa Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 6% to 6%.
Source: South Africa Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: South Africa Treaty Reference
Comparative Context
🇮🇹Italy's Network
Among Italy's 47 active treaty partners, the 15% general dividend rate ranks 47th (median: 15%).
| Partner | Rate |
|---|---|
| Turkey | 15% |
| United States | 15% |
| Vietnam | 15% |
| South Africa (this treaty) | 15% |
🇿🇦South Africa's Network
Among South Africa's 37 active treaty partners, the 15% general dividend rate ranks 25th (median: 15%).
| Partner | Rate |
|---|---|
| Indonesia | 15% |
| Ireland | 15% |
| Israel | 15% |
| Italy (this treaty) | 15% |
| Japan | 15% |
| South Korea | 15% |
| Luxembourg | 15% |