SARS Double Taxation Agreements: Full Country List and Guide

South Africa has SARS double taxation agreements (DTAs) with over 79 countries. A DTA is an agreement between two countries that prevents the same income from being taxed twice. If you’re a South African expat earning money abroad, or a non-resident earning income from South African sources, the DTA between SA and your country determines which country gets to tax what, and at what rate.

This guide explains what DTAs are, how they work, what they cover, and which countries have treaties with South Africa. It also covers the tie-breaker rules that resolve dual residency, the common myths about DTAs, and how SARS shares your information with over 100 countries through the Common Reporting Standard.

What Is a Double Taxation Agreement?

A Double Taxation Agreement (also called a DTA, tax treaty, or double tax convention) is a formal agreement between South Africa and another country. Its purpose is to set clear rules about which country has the right to tax specific types of income, so the same money doesn’t get taxed in both countries.

Without a DTA, a South African tax resident working in the UK could be taxed by both SARS and HMRC on the same salary. That would mean losing a huge chunk of income to tax in two countries at the same time. The DTA prevents this by allocating taxing rights and requiring one country to give a credit or exemption for the tax paid in the other.

DTAs carry the full weight of South African law. Under Section 108(2) of the Income Tax Act, once a DTA is approved by Parliament and published in the Government Gazette, it has effect as if it were written directly into the Income Tax Act itself. This means that if a DTA conflicts with domestic tax law, the DTA takes precedence.

How SARS Double Taxation Agreements Help Expats

For South African expats, DTAs do four main things.

They prevent double taxation. The most obvious benefit. The DTA determines which country taxes your salary, your pension, your rental income, your dividends, and your interest. In most cases, one country gets the primary right and the other gives a credit or exemption.

They resolve dual residency through tie-breaker rules. If both South Africa and another country consider you a tax resident under their domestic laws, the DTA contains tie-breaker provisions that determine which country wins. The tie-breaker typically looks at where your permanent home is, where your centre of vital interests lies (family, economic ties), where you habitually live, and your nationality. For more on how these tests work, see our guide to the South African tax residency test.

They reduce withholding tax rates. Without a DTA, South Africa applies standard withholding tax rates on payments to non-residents (20% on dividends, 15% on interest, 15% on royalties). A DTA often reduces these rates significantly. For example, the SA-UK DTA caps dividend withholding at 5-15% depending on ownership levels.

They can be used to cease tax residency. If the DTA determines you’re exclusively resident in the other country, you can use this as the basis for ceasing your SA tax residency (Qualifying Basis 3 on the SARS cessation process).

Countries With SARS Double Taxation Agreements (Full List)

South Africa has the largest DTA network of any country in Africa. The following table shows all countries with active (in-force) DTAs with South Africa. This list is based on the official SARS Status Overview document (last updated November 2024) and the PwC Worldwide Tax Summaries database (reviewed May 2026).

South Africa also has signed but not yet ratified DTAs with Gabon and Sudan. Renegotiated treaties with Malawi, Zambia, and Germany are in various stages of the ratification process. For the latest official status, check the SARS DTA status overview document on the SARS website.

Notable Countries WITHOUT a DTA with South Africa

Some popular expat destinations do not have a DTA with South Africa. This is worth knowing because without a DTA, there’s no treaty mechanism to prevent double taxation or resolve dual residency. Countries with large South African expat communities that have no DTA include New Zealand (which does have one), but places like Vietnam, Cambodia, Philippines, Argentina, Colombia, Peru, and many Caribbean nations do not.

If you live in a country without a DTA, you may still get relief from double taxation through South Africa’s Section 6quat foreign tax credit, which allows you to offset foreign tax paid against your SA tax liability. But this is domestic law relief, not treaty relief, and it doesn’t include the tie-breaker or withholding rate benefits that a DTA provides.

What a DTA Covers (The Standard Articles)

Most SARS double taxation agreements follow the OECD Model Tax Convention structure, with some elements from the UN Model. Here’s what the typical DTA covers, explained for individuals.

Employment income. The country where you perform the work generally has the right to tax your salary. But there’s an important exception. If you work in another country for fewer than 183 days in any 12-month period, your employer is not a resident of that country, and your salary isn’t borne by a permanent establishment there, then only your country of residence taxes you. This is the 183-day employment income exemption that most DTAs contain.

Pensions and annuities. Each DTA handles pensions differently. Some give exclusive taxing rights to the country of residence (meaning the country you live in, not SA). Others allow both countries to tax, with the residence country giving credit for tax paid in the source country. You need to check the specific DTA for your country. For South African living annuities and retirement annuity income, the UK and Australian DTAs are particularly favourable, often exempting this income from PAYE in SA. See our UK guide for details on how the UK-SA DTA works.

Dividends, interest, and royalties. DTAs typically cap the withholding tax that the source country (where the income originates) can charge. Without a DTA, South Africa’s domestic withholding rates apply (20% on dividends, 15% on interest, 15% on royalties). With a DTA, these rates are often reduced to 5-10%.

Capital gains. For individuals, capital gains on immovable property (real estate) are always taxable in the country where the property is located, regardless of the DTA. Capital gains on other assets (shares, investments) are typically only taxable in the country of residence.

Elimination of double taxation. Every DTA includes an article specifying how double taxation is eliminated. South Africa uses the credit method rather than the exemption method. This means if both countries are allowed to tax the same income, South Africa gives you a credit for the foreign tax you’ve already paid, up to the amount of SA tax that would have been due on that income.

Common Myths About SARS Double Taxation Agreements

“I have a DTA, so I’m automatically exempt from SA tax.” Wrong. Having a DTA between SA and your country does not automatically exempt you from anything. You must formally apply the DTA provisions and claim the exemption when filing your tax return. SARS will not apply treaty relief on your behalf.

“A DTA means I don’t need to file a return.” Also wrong. Even if the DTA means you owe no tax in SA, you still need to file your tax return and claim the relief. Failing to file can result in penalties and may undermine any future DTA claims.

“Having a foreign passport removes SA taxing rights.” Citizenship and tax residency are separate. Having another country’s passport doesn’t change your tax residency status with SARS.

SARS Can See Your Foreign Income (CRS and AEOI)

Something many expats don’t realise is that SARS shares information with over 100 countries through the Common Reporting Standard (CRS) and the Automatic Exchange of Information (AEOI) framework. This means foreign banks, investment companies, and financial institutions report your account details and investment income to their local tax authority, which then sends that information to SARS.

The February 2026 SARS publication on Automatic Exchange of Information confirmed this system is fully operational. SARS uses this data, combined with domestic information (SA banking, property ownership, directorships, medical aid, vehicle registrations), to build risk profiles of taxpayers who claim non-residency but whose financial footprint suggests otherwise.

This is especially relevant for expats who have left SA without formally ceasing tax residency. If SARS can see you earning income in the UK but your status still shows “Resident” on eFiling, they can assess you on that worldwide income, potentially going back multiple years with interest and penalties.

How to Get a Tax Residency Certificate from SARS

If you need to prove to a foreign country that you’re a SA tax resident (to claim treaty benefits in that country), you can request a Certificate of Residence from SARS. This involves downloading and completing the RC01 form (for individuals) from the SARS website, signing it, and submitting it via eFiling, email to contactus@sars.gov.za, or at a SARS branch.

SARS takes about 21 business days to process the request if the form is complete and no additional information is needed. The certificate is valid for one year from the date of issue. Your tax returns must be up to date before SARS will issue it.

The Mutual Agreement Procedure (MAP)

If you believe your income has been taxed incorrectly under a DTA, and you can’t resolve it through normal channels, the DTA includes a Mutual Agreement Procedure. This lets you ask the “competent authorities” of both countries (SARS is the competent authority for South Africa) to negotiate and resolve the dispute. MAP only applies to the tax itself, not to penalties or interest.

Related Guides

• South African Expat Tax (Complete Guide)
• SA Expat Tax in the UK
• The South African Tax Residency Test
• How to Cease Tax Residency in South Africa
• SARS Exit Tax
• Financial Emigration South Africa
• Retirement Fund Withdrawal From Abroad
• Leaving South Africa Tax Guide