31/08/2026
A Double Taxation Agreement (“DTA”) is not applied in isolation from a taxpayer’s broader compliance position with SARS.
Applications for non-resident tax status are now assessed with greater attention to whether the taxpayer’s overall profile supports a treaty-based claim, including the resolution of any outstanding tax obligations.
This reflects SARS’ increasing focus on ensuring that treaty relief is both factually supported and consistent with the taxpayer’s full compliance history.
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