Australian Tax Treaties
The Government of Australia and the Government of the Republic of South Africa shall notify each other in writing through the diplomatic channel of the completion of their domestic requirements for the entry into force of this Protocol.
2.
The Protocol, which shall form an integral part of the Agreement, shall enter into force on the date of the last notification, and thereupon the Protocol shall have effect:
(a) in the case of Australia:
(i) with regard to withholding tax on income that is derived by a nonresident, in respect of income derived on or after the first day of the second month following the date on which the Protocol enters into force;
(ii) with regard to other Australian tax, in respect of income, profits or gains of any year of income beginning on or after 1 July in the calendar year next following the date on which the Protocol enters into force;
(b) in the case of South Africa:
(i) with regard to taxes withheld at source, in respect of amounts paid or credited from the day after the date on which the Protocol enters into force;
(ii) with regard to other South African tax, in respect of years of assessment beginning on or after 1 January next following the date on which the Protocol enters into force;
(c) for purposes of Article 25 from the date on which the Protocol enters into force; and
(d) for purposes of Article 25A, from a date to be agreed in an Exchange of Notes through the diplomatic channel.
[ CCH Note: Article 25A entered into force on 1 July 2010 ( Commonwealth of Australia Gazette, No GN 47, 1 December 2010, 2783 ).]
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