Luxembourg – South Africa Tax Treaty
The Luxembourg-South Africa tax treaty caps withholding on dividends at 15% for portfolio investors and 5% for qualifying direct investment, with interest payments fully exempt at 0%. Royalties are taxed at a uniform 0% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 27 active treaties in Luxembourg's network and one of 37 in South Africa's. The general dividend rate of 15% compares to a median of 15% across Luxembourg's network and 15% across South Africa's.
Verified data
ACD International Tax Conventions (impotsdirects.public.lu) (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12). Luxembourg has 0% domestic WHT on interest and royalties.)
Withholding Rate Summary
Source: Luxembourg Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Luxembourg) |
|---|---|---|
| Dividends (general) Portfolio investors | 15% | 15% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 10% | 15% |
| Interest Bank interest, bonds, loans | 0% | 0% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 0% | — |
| 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 (Luxembourg)” 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 15%.
Source: Luxembourg Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 0% withholding under this treaty, compared to the 0% statutory rate. Interest is fully exempt from source-country withholding under this treaty.
Source: Luxembourg Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 0% to 0%.
Source: Luxembourg 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: Luxembourg Treaty Reference
Comparative Context
🇱🇺Luxembourg's Network
Among Luxembourg's 27 active treaty partners, the 15% general dividend rate ranks 27th (median: 15%).
| Partner | Rate |
|---|---|
| Sweden | 15% |
| Turkey | 15% |
| United States | 15% |
| South Africa (this treaty) | 15% |
🇿🇦South Africa's Network
Among South Africa's 37 active treaty partners, the 15% general dividend rate ranks 28th (median: 15%).
| Partner | Rate |
|---|---|
| Italy | 15% |
| Japan | 15% |
| South Korea | 15% |
| Luxembourg (this treaty) | 15% |
| Norway | 15% |
| New Zealand | 15% |
| Pakistan | 15% |