The purpose of double tax agreements (“DTA” or “treaty”) between the tax administrations of two countries is to enable the administrations to eliminate double taxation, where each country intends to levy a tax in respect of the same amount of personal income. South Africa has a very favourable treaty network across the world. Generally, the provisions of double tax agreements have preference over local legislation, so one needs to take notice when a court delivers judgment on a matter contained in a DTA. The Supreme Court in the United Kingdom (UK) recently delivered judgement in Fowler (Respondent) v Commissioners for […]