Article 1 - Personal scope - South Africa

MINISTRY OF FINANCE (Department of Revenue) NOTIFICATION New Delhi, the 21st April, 1998 INCOME-TAX South Africa G.S.R. 198(E). --Whereas the annexed agreement between the Government of the Republic of India and the Government of the Republic of South Africa for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, has entered into force on the twenty-eighth day of November, 1997, in accordance with Article 28 of the said Agreement, after the notification by both the contracting States to each other of the completion of the procedures required under their laws for the bringing into force of the said agreement; Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby directs that all the provisions of the said agreement shall be given effect to in the Union of India. Annexure Agreement Between the Government of the Republic of India and the Government of the Republic of South Africa for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Preamble The Government of the Republic of India and the Government of the Republic of South Africa desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, Have agreed as follows : ARTICLE 1 PERSONAL SCOPE This Agreement shall apply to persons who are residents of one or both of the Contracting States.