n South African Law Journal - Taxing the partner of a foreign partnership : notes

Volume 125, Issue 3
  • ISSN : 0258-2503
  • E-ISSN: 1996-2177



The recent 2007 tax case ITC 1819 (2007) 69 SATC 159 is noteworthy on two grounds. First, it is one of only a few South African tax cases dealing with the application and interpretation of double taxation agreements (DTAs), in this instance an agreement concluded between Lesotho and South Africa. Secondly, it highlights two crucial issues in such cases, namely the importance of determining the correct tax-paying entity and the interaction between DTAs and domestic tax legislation.

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