South African residents pay tax on their foreign dividends. However, various exemptions apply. In particular, where a resident of South Africa holds at least 20% of the ordinary shares in the declaring company and various other conditions are met, the foreign dividends are exempt from tax in the hands of the South African resident recipient.
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The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year