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As I read section 64N there is a credit for foreign dividends - actually a REBATE against our 20% tax. So as I understand it if the foreign rate is 25%
as it seems to be in the case of the SYGEU then no SA tax is payable. Makes sense - pity the excess rate cannot be offset against other dividends recieved here.
( while I know I am pushing this it seems unfair towards induviduals on the part of our income tax act)
So the first question is WHOSE withholding rate is being charged here? The EU may have some member common dividend tax rate overlay - at 25% which is the rate here?
But in the case of the UK the withholding rate seems to be markedly less less than 20% - but this is not a rebate - in their announcements it cancels out the SA DWT rate completely.
Can anyone - Simon!!! - EXPLAIN.( please )
As to the rate applied - it occurs as it shold have before I put pen to paper origianlly that this is the cumulative DWT deducted at source....as opposed to some overarching rate - ?
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