United Arab Emirates – South Africa Tax Treaty
The United Arab Emirates-South Africa tax treaty caps withholding on dividends at 10% for portfolio investors and 5% for qualifying direct investment, with interest payments fully exempt at 0%. Royalties are taxed at a uniform 10% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 21 active treaties in United Arab Emirates's network and one of 37 in South Africa's. The general dividend rate of 10% compares to a median of 10% across United Arab Emirates'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 | 10%saves 10% | 20% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 15% | 20% |
| Interest Bank interest, bonds, loans | 0% | 0% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 10% | — |
| 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 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 0% withholding under this treaty, compared to the 0% statutory rate. Interest is fully exempt from source-country withholding under this treaty.
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 10% to 10%.
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
🇦🇪United Arab Emirates's Network
Among United Arab Emirates's 21 active treaty partners, the 10% general dividend rate ranks 13th (median: 10%).
| Partner | Rate |
|---|---|
| Malaysia | 10% |
| Netherlands | 10% |
| Thailand | 10% |
| South Africa (this treaty) | 10% |
| Turkey | 12% |
| Australia | 15% |
| Canada | 15% |
🇿🇦South Africa's Network
Among South Africa's 37 active treaty partners, the 10% general dividend rate ranks 2nd (median: 15%).
| Partner | Rate |
|---|---|
| Saudi Arabia | 5% |
| United Arab Emirates (this treaty) | 10% |
| China | 10% |
| Cyprus | 10% |
| India | 10% |