Nigeria – South Africa Tax Treaty
The Nigeria-South Africa tax treaty caps withholding on dividends at 10% for portfolio investors and 7.5% for qualifying direct investment, and interest at 7.5%. Royalties are taxed at a uniform 7.5% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 3 active treaties in Nigeria's network and one of 37 in South Africa's. The general dividend rate of 10% is below the median in both countries' treaty networks (Nigeria: 15%, South Africa: 15%).
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 | 10%saves 10% | 20% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 7.5%saves 12.5% | 20% |
| Interest Bank interest, bonds, loans | 7.5% | 0% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 7.5% | — |
| 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 10% applies to portfolio investors. A reduced rate of 7.5% 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 7.5% 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 7.5% to 7.5%.
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
🇳🇬Nigeria's Network
Among Nigeria's 3 active treaty partners, the 10% general dividend rate ranks 1st (median: 15%).
| Partner | Rate |
|---|---|
| South Africa (this treaty) | 10% |
| Canada | 15% |
| United Kingdom | 15% |
🇿🇦South Africa's Network
Among South Africa's 37 active treaty partners, the 10% general dividend rate ranks 7th (median: 15%).
| Partner | Rate |
|---|---|
| Cyprus | 10% |
| India | 10% |
| KE | 10% |
| Nigeria (this treaty) | 10% |
| Netherlands | 10% |
| Singapore | 10% |
| Australia | 15% |