Dividends Tax replaces Secondary Tax on April 1, 2012

On December 20, 2011 the South African Minister of Finance formally announced that on April 1, 2012 the Dividends Tax will replace the Secondary Tax on Companies ("STC"). The 10% STC rate is levied on net dividends declared. STC is not a shareholder-level tax, but is instead a tax imposed on the company declaring the dividend. As such the tax does not qualify for treaty relief.