Tag Archives: tax treaties south africa

South Africa: The unintended consequences of Most Favoured Nation Clauses in Tax treaties

By Francis Mayebe, Candidate Attorney, overseen by Virusha Subban, Partner and Head of Tax, Baker McKenzie Johannesburg Background Bilateral tax treaties are mainly based on the principle of reciprocity. Under this principle, one state negotiates better treaty terms with another in exchange for making a particular concession. As is clearly seen in most protocols, the […]