When a company is considered to be established in the two contracting states, the competent authorities determine the place of residence of the company for the purposes of the treaty, by mutual agreement, on the basis of the place of effective administration, the place where it is registered or otherwise constituted, as well as other relevant factors. In the absence of an agreement, the company is not entitled to the exemption or exemption under the contract, unless the competent authority has agreed to do so. Under source rules, few foreign taxed property is subject to Zimbabwean tax. However, there is a general unilateral provision to exempt double taxation. The contract provides that a stable establishment is considered constituted when a company provides services within a contracting state through workers or other staff engaged for the same project or related project for a period or period covering more than 183 days over a 12-month period. The agreement also applies to all identical or essentially similar taxes levied after the date of signing the agreement, in addition to or in place of existing taxes. The competent authorities of the contracting states inform each other of any substantial changes to their respective tax laws. For taxes paid on foreign income, tax relief is allowed in the form of a Zimbabwean tax credit. The total amount of the authorized credit must not exceed an amount equal to Zimbabwe`s total tax equal to that of foreign taxable income in Zimbabwe in relation to total taxable income. The contract applies to withholding tax from February 1, 2017 and other taxes from January 1, 2017. The 1965 Income Tax Convention between the two countries ceases to enter into force with respect to each tax for each period for which the new treaty applies. 1.
This agreement applies to the taxation of income collected on behalf of a contracting state or its political subdivisions, regardless of how they are collected.2. Income tax is considered to be all taxes levied on total income or income, including taxes on profits derived from the disposal of property or real estate.3 The existing taxes to which this agreement applies are:a) in South Africa: (i) the normal tax; (ii) dividend tax; (iii) withholding tax on royalties; (iv) the tax on foreign artists and athletes; and (v) withholding tax on interest; (the so-called “South African tax”); b) Zimbabwe: (i) income tax;ii) non-resident shareholder tax; (iii) non-resident tax on royalties; (iv) tax on non-resident royalties; (v) capital gains tax; and (vi) the taxation of residents on interest; (hereafter referred to as the “Zimbabwe tax”).