Latest Treaty Updates: South Africa


Treaty Update: South Africa - Saint Kitts and Nevis

22/2/2017

The TIEA between South Africa and Saint Kitts and Nevis is to enter into force on February 18, 2017.


Treaty Update: South Africa - Chile

16/9/2016

According to a September 9 notice from the South African Revenue Service, the DTA with Chile entered into force on August 11.


Treaty Update: South Africa - Lesotho

6/7/2016

South Africa published a notice on June 24, 2016, confirming that its DTA with Lesotho entered into force on May 27.


Treaty Update: Zimbabwe - South Africa

28/4/2016

Zimbabwe on April 8, 2016, ratified the DTA with South Africa.


Treaty Update: South Africa - Qatar

22/2/2016

South Africa completed its domestic ratification procedures in respect of the DTA with Qatar on February 11, 2016, publishing the text of the agreement in the Official Gazette.


Treaty Update: South Africa - Cyprus

22/10/2015

South Africa published a notice in its Official Gazette on October 16, 2015, to ratify the DTA Protocol signed with Cyprus. The Protocol entered into force on September 18.


Treaty Update: Bangladesh - South Africa

26/8/2015

Bangladesh and South Africa have committed to continuing negotiations towards a double tax agreement, the Bangladesh Ministry of Foreign Affairs said on August 19, 2015.


Treaty Update: South Africa - Uruguay

20/8/2015

South Africa and Uruguay signed a DTA on August 7, 2015.


Treaty Update: South Africa - Brazil

17/8/2015

South Africa and Brazil signed a DTA Protocol on July 31, 2015.


Treaty Update: South Africa - Zimbabwe

13/8/2015

South Africa and Zimbabwe signed a new DTA to replace their 1965 agreement on August 4, 2015.


Treaty Update: Hong Kong - South Africa

31/7/2015

According to a July 21 update from the South African Revenue Service, Hong Kong has newly ratified the DTA the territory signed with South Africa.


Treaty Update: South Africa - Mauritius

25/6/2015

South Africa completed its domestic ratification procedures in respect of the DTA with Mauritius on June 17, 2015, publishing a notification in its Official Gazette. The DTA entered into force on May 28, 2015, and it will be effective from January 1, 2016.


Treaty Update: South Africa - Various

23/6/2015

According to a June 8 update from the South African Revenue Service, South Africa's TIEAs with Belize and Liechtenstein entered into force on May 23, 2015.


Treaty Update: South Africa - Turks and Caicos Islands

22/6/2015

According to a June 8 update from the South African Revenue Service, South Africa signed a TIEA with the Turks and Caicos Islands on May 27, 2015.


Treaty Update: Turks and Caicos Islands - South Africa

11/6/2015

According to preliminary media reports, the Turks and Caicos Islands signed a TIEA with South Africa on May 27, 2015.


Treaty Update: South Africa - Various

3/6/2015

Reports concerning South Africa's pending DTAs With Lesotho, Cameroon, and Qatar, and a Protocol with Cyprus, were tabled before South Africa's Parliament on May 12, 2015, as part of the nation's domestic ratification procedures.


Treaty Update: Cyprus - South Africa

10/4/2015

Cyprus and South Africa signed a Protocol to their DTA on April 1, 2015.


Treaty Update: South Africa - Barbados

20/2/2015

A notice was published in the South Africa official gazette on February 17, 2015, reporting that the TIEA with Barbados entered into force on January 19, 2015.


Treaty Update: South Africa - Grenada

23/1/2015

South Africa signed a TIEA with Grenada on December 10, 2014.


Treaty Update: South Africa - Cook Islands

19/1/2015

The TIEA between South Africa and the Cook Islands came into force on January 8, 2015.


Treaty Update: Hong Kong - South Africa

21/10/2014

Hong Kong signed a DTA with South Africa on October 16, 2014.


Treaty Update: South Africa - Lesotho

2/10/2014

South Africa signed a second DTA with Lesotho on September 18, 2014, to replace the one that has been effective since 1997.


Treaty Update: South Africa - Various

6/8/2014

South Africa's parliament on July 31, 2014, approved laws to ratify two Protocols to amend the nation's double tax agreements with Turkey and India.


Treaty Update: South Africa - Malta

28/1/2014

The South African Revenue Service published a notice on January 24, 2014, confirming that the DTA Protocol signed with Malta on August 24, 2012, entered into force on December 17, 2013.


Treaty Update: Turkey - South Africa

6/1/2014

Turkey confirmed on December 13, 2013, the signing of a DTA Protocol with South Africa to add tax information exchange provisions.


Treaty Update: Cook Islands - South Africa

19/11/2013

According to preliminary media reports, the Cook Islands and South Africa signed a TIEA on October 25, 2013.


Treaty Update: Malta - South Africa

15/11/2013

Malta completed its domestic ratification procedures in respect of the DTA Protocol signed with South Africa on November 8, 2013, publishing The Double Taxation Relief (Taxes on Income) (South Africa) (Amendment) Order, 2013, in its Official Gazette.


Treaty Update: South Africa - Costa Rica

14/10/2013

On October 8, 2013, a law to ratify the TIEA signed between South Africa and Costa Rica was tabled before South Africa's upper house of parliament, the National Council of Provinces, on October 8, 2013.


Treaty Update: South Africa - Various

14/10/2013

South Africa's upper house of parliament, the National Council of Provinces, on October 8, 2013, considered laws to ratify the DTA Protocols signed with Botswana, Malta, and a DTA signed with Chile.


Treaty Update: Monaco - South Africa

7/10/2013

Monaco and South Africa signed a Tax Information Exchange Agreement on September 23, 2013.


Treaty Update: South Africa - Various

17/9/2013

At its meeting on September 12, 2013, South Africa's parliament approved tax information exchange agreements signed with Samoa and Costa Rica.


Treaty Update: South Africa - Various

17/9/2013

South Africa's parliament on September 12, 2013, approved three Protocols amending the nation's DTAs with Oman, Norway and Malta; and a DTA signed with Chile.


Treaty Update: South Africa - Various

13/8/2013

South Africa's Select Committee on Finance will, on August 13, 2013, discuss two Protocols to South Africa's DTAs with Botswana and Oman, and a new DTA signed with Mauritius.


Treaty Update: South Africa - Gibraltar

16/7/2013

According to preliminary media reports, Gibraltar's TIEA with South Africa will enter into force on July 21, 2013.


Treaty Update: South Africa - Botswana

2/7/2013

South Africa's Standing Committee on Finance endorsed the Protocol signed to amend the nation's DTA with Botswana, forwarding it to the nation's parliament for approval on June 19, 2013.


Treaty Update: South Africa - Various

25/6/2013

South Africa's TIEAs with Samoa and Costa Rica were forwarded to the nation's parliament for its approval on June 18, 2013.


Treaty Update: South Africa - Oman

25/6/2013

Protocols to South Africa's DTAs with Oman, Norway and Malta, and a DTA with Chile, were forwarded to South African parliament for its approval on June 21, 2013.


Treaty Update: South Africa - Various

10/5/2013

South Africa's DTA Protocols with Oman, Norway, Malta, and Costa Rica, and a DTA with Chile were approved by the nation's National Assembly at its meeting on May 8, 2013.


Treaty Update: Qatar - South Africa

11/4/2013

Qatari Sultan Qaboos bin Said on April 9, 2013 ratified the pending DTA Protocol the nation signed with South Africa.


Treaty Update: South Africa - Various

10/4/2013

South Africa's DTA Protocol with Norway and Malta; its DTAs with Chile and Samoa; and a tax information exchange agreement with Costa Rica was forwarded to South African parliament for its approval on March 27, 2013.


Treaty Update: South Africa - Various

1/1/2013

According to information published by the South African Revenue Service, the two DTA Protocols signed with Ireland and Austria entered into force on February 10, 2012, and March 1, 2012, respectively, and became effective on January 1, 2013. In addition, the new DTA South Africa signed with the Congo on April 29, 2005, entered into force on July 18, 2012, and also becomes effective on January 1, 2013.


Treaty Update: South Africa - Ireland

28/11/2012

According to information published by the Irish revenue Commissioners, the protocol to the Ireland-South Africa DTA, which entered into force on February 10, 2012, will be effective in full from January 1, 2013. Articles three and six of the Protocol became effective on April 1, 2012.


Treaty Update: Liechtenstein - South Africa

27/11/2012

Liechtenstein's government has announced that Liechtenstein and South Africa signed a TIEA on November 21, 2012.


Treaty Update: South Africa - Hong Kong

1/11/2012

According to preliminary media reports, representatives from Hong Kong and South Africa are to commence five-day long negotiations towards the conclusion of a DTA.


Treaty Update: Costa Rica - South Africa

31/10/2012

According to preliminary media reports, Costa Rica and South Africa signed a TIEA on October 27, 2012.


Treaty Update: South Africa - Various

27/9/2012

Legislation to ratify the TIEAs signed between South Africa and Gibraltar, Liberia and Dominica, was tabled before South Africa's parliament for its approval on August 28, 2012.


Treaty Update: Malta - South Africa

4/9/2012

According to preliminary media reports, Malta and South Africa signed a DTA Protocol on August 24, 2012.


Treaty Update: South Africa - Various

25/7/2012

The South African Revenue Service (SARS) has announced that the 34 nations party to the African Tax Administration Forum are expected to conclude negotiations towards a multilateral tax information exchange agreement when the they hold three days of meetings which conclude on July 27, 2012. These nations include Benin, Botswana, Burundi, Cameroon, Chad, Comores, The Gambia, Ghana, Kenya, Lesotho, Madagascar, Malawi, Mauritius, Mozambique, Namibia, Niger, Nigeria, Rwanda, Senegal, Seychelles, South Africa, Swaziland, Tanzania, Uganda, Zambia and Zimbabwe.


Treaty Update: Norway - South Africa

25/7/2012

According to preliminary media reports, South Africa and Norway on July 16, 2012 signed a Protocol amending the DTA between the two countries.


Treaty Update: South Africa - Zimbabwe

16/7/2012

According to preliminary media reports, South Africa and Zimbabwe on July 5, 2012, concluded three-days of negotiations towards a double tax agreement.


Treaty Update: Chile - South Africa

13/7/2012

According to the South African government, Chile and South Africa agreed the terms of a DTA on July 6, 2012.


Treaty Update: Seychelles - South Africa

13/6/2012

According to the South African Revenue Service, the DTA signed between the Seychelles and South Africa entered into force on May 15, 2012.


Treaty Update: South Africa - Oman

23/5/2012

At its sitting on May 16, 2012, South Africa's parliament considered an amending protocol to the South Africa-Oman DTA.


Treaty Update: Sweden - South Africa

1/5/2012

The Swiss Embassy in Pretoria has announced that a DTA between Sweden and South Africa entered into force on March 18, 2012.


Treaty Update: Malaysia - South Africa

3/4/2012

The Protocol to the DTA between Malaysia and South Africa entered into force on March 6, 2012, the South African tax authority has confirmed.


Treaty Update: South Africa - San Marino

3/4/2012

On March 23, 2012, the South African government published the TIEA between South Africa and San Marino in the nation's Official Gazette as part of the its ratification procedures.


Treaty Update: South Africa - Ireland

27/3/2012

On March 22, 2012, the South African government published the Protocol to the DTA between South Africa and Ireland in the nation's Official Gazette as part of the its ratification procedures.


Treaty Update: Ireland - South Africa

7/3/2012

According to information posted on the Irish Revenue Commission website, the DTA Protocol signed between Ireland and South Africa entered into force on February 10, 2012. The Protocol's provisions in relation to dividends and information exchange will be effective from April 1, 2012.


Treaty Update: South Africa - Various

6/3/2012

The South African tax authority has confirmed the entry into force of the nation's TIEAs with Bermuda on February 27, 2012, Guernsey on February 26, 2012, and Jersey on February 29, 2012.


Treaty Update: Jersey - South Africa

2/3/2012

The TIEA between Jersey and South Africa entered into force on February 29, 2012.


Treaty Update: Austria - South Africa

2/3/2012

The pending Protocol to the existing 1996 DTA between South Africa and Austria entered into force on March 1, 2012.


Treaty Update: Cayman Islands - South Africa

28/2/2012

According to preliminary media reports, the TIEA between the Cayman Islands and South Africa entered into force on February 23, 2012.


Treaty Update: Guernsey - South Africa

24/2/2012

According to preliminary media reports, the TIEA between Guernsey and South Africa will enter into force on February 26, 2012.


Treaty Update: South Africa - United Kingdom

8/2/2012

The Protocol to the UK-South Africa DTA, signed on July 4, 2002, was published in South Africa's Official Gazette on February 2, 2012, as part of the country's ratification procedure.


Treaty Update: Gibraltar - South Africa

6/2/2012

The government of Gibraltar has announced Gibraltar and South Africa signed a TIEA on February 2, 2012.


Treaty Update: South Africa - San Marino

31/1/2012

South Africa's TIEA with San Marino was published in South Africa's Gazette on January 28, 2012, and entered into force immediately.


Treaty Update: South Africa - Hong Kong

20/12/2011

Hong Kong's Financial Secretary John Tsang has confirmed that during meetings between government officials on December 13, 2011, South Africa and Hong Kong have agreed to open negotiations towards a bilateral DTA.


Treaty Update: South Africa - Various

14/12/2011

According to preliminary media reports, on December 1, 2011, South Africa's parliament ratified pending TIEAs between South Africa and the Bahamas, Bermuda, the Cayman Islands, Guernsey, Jersey and San Marino.


Treaty Update: South Africa - Various

14/12/2011

According to preliminary media reports, South Africa's parliament on December 1, 2011, ratified DTAs signed between South Africa and Austria, Malaysia and the Seychelles.


Treaty Update: Oman - South Africa

17/11/2011

Oman and South Africa signed an amending protocol to their 2002 DTA during meetings on November 15, 2011, which would, among other provisions, provide legal protection to investors in both countries.


Treaty Update: South Africa - United Kingdom

24/10/2011

According to preliminary media reports, an amending protocol to the DTA between the United Kingdom and South Africa, signed in November 2010, entered into force on October 13, 2011.


Treaty Update: Congo, Democratic Republic of the - South Africa

22/9/2011

According to preliminary media reports, Congo has ratified the pending double tax agreement signed between the nation and South Africa. According to South Africa's tax authority, the agreement has already been ratified by South Africa.


Treaty Update: Bermuda - South Africa

8/9/2011

The TIEA between Bermuda and South Africa was signed by Bermuda Finance Minister Paula Cox on September 6. The agreement has already been signed by South Africa and must be ratified by both countries before it can enter into force.


Treaty Update: San Marino - South Africa

5/8/2011

According to preliminary media reports, the Tax Information Exchange Agreement signed with South Africa was ratified by San Marino's legislative assembly on July 21, 2011.


Treaty Update: South Africa - Zambia

7/7/2011

According to media reports, three African nations, South Africa, Zambia and Tanzania are engaged in talks to formalize bilateral tax information exchange, potentially through the signing of Tax Information Exchange Agreements.


Treaty Update: South Africa - Tanzania

7/7/2011

According to media reports, three African nations, South Africa, Zambia and Tanzania are in talks to formalize bilateral tax information exchange, potentially through the signing of Tax Information Exchange Agreements.


Treaty Update: South Africa - Serbia

5/7/2011

According to the South African government, representatives from South Africa and Serbia will consider the signature of a drafted Double Tax Convention during two-day talks, due to commence on July 4, 2011.


Treaty Update: South Africa - San Marino

27/5/2011


Treaty Update: South Africa - Cayman Islands

27/5/2011


Treaty Update: South Africa - Guernsey

27/5/2011

In South Africa, the TIEA applies to the normal tax, secondary tax on companies, withholding tax on royalties, tax on foreign entertainers and sportspersons and VAT. In Guernsey the TIEA applies to income tax and dwellings profit tax. The TIEA provides for the exchange of information relevant to the administration and enforcement of domestic tax laws, and the determination, assessment and collection of taxes, the recovery and enforcement of tax claims, and the investigation/prosecution of tax matters. The TIEA also provides for the exchange of information held by banks and other financial institutions, and information regarding the ownership of companies, partnerships, and, in certain cases, investment funds or schemes, trusts and foundations. The TIEA also contains a mutual assistance procedure and a mutual agreement procedure.


Treaty Update: Ireland - South Africa

26/5/2011

The Protocol was signed on March 17, 2010. The Protocol adds a clause providing for the treaty to extend to the intoduction of any identical or substantially similar taxes imposed following the treaty's signature, including taxes on dividends. The Protocol also amends the definition of resident. Dividend withholding tax is altered, so that: 5% is charged where the beneficial owner is a company holding directly at least 10% of the capital of the paying company, and at 10% in all other cases. The Protocol also provides for the exchange of information to international standards.




Treaty Updates by Territory


Latest News


SARS Modifies Ruling On Taxes Applicable To DTAs 6/2/2017
The South African Revenue Service has issued a revised binding general ruling that identifies the taxes administered by the agency that constitute taxes on income for the purposes of South Africa's double taxation agreements.

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South Africa Confirms DTA With Chile In Effect 19/9/2016
According to a notice published on September 9 by the South African Revenue Service, the double taxation agreement between South Africa and Chile, which was signed on July 11, 2012, went into force on August 11, 2016.

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South Africa CRS Regulations Come Into Effect 3/3/2016
The South African Revenue Service has issued final regulations that require certain financial institutions to report on accounts held or controlled by foreign residents from March 1, 2016.

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SARS Explains 2015 Tax Administration Amendments 22/12/2015
On December 17, the South African Revenue Service issued an explanatory memorandum on the 2015 Tax Administration Laws Amendment Bill.

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South Africa Ratifies Tax Treaty With Mauritius 24/6/2015
The South African Treasury has noted the entry into force of a new double tax agreement with Mauritius, which was published in the Official Gazette on June 17, 2015.

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Hong Kong, South Africa Sign DTA 21/10/2014
On October 16, Hong Kong and South Africa signed a comprehensive double taxation agreement – the 31st such agreement that Hong Kong has concluded.

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SARS Disclosure Rule Surpasses FATCA Needs 8/4/2014
The South Africa Revenue Service has proposed new disclosure requirements for South African financial institutions, to simplify compliance with the United States's Foreign Account Tax Compliance Act and also expand the nation's access to information relevant to its own domestic tax investigations.

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G20 Forging Ahead With Anti-Avoidance Action 9/9/2013
The G20 group of nations has endorsed plans to make the automatic exchange of tax information the global standard, and agreed to steps for cracking down on base erosion and profit shifting.

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South Africa, Mauritius DTA Revisions Could Catch Out Multinationals 30/5/2013
According to Johan Hatting, PricewaterhouseCoopers' senior international tax manager, the revised double taxation agreement between South Africa and Mauritius, which was signed on May 17 this year and should, from January 1, 2015, replace the original treaty signed in July 1996, could prove problematic for South African multinationals.

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Netherlands Updates Tax Treaty Negotiation Program 1/5/2013
Underlining the Government's ongoing commitment to concluding bilateral tax treaties with other countries, the Dutch Finance Ministry has recently listed the countries with which the Netherlands plans to begin negotiations on a tax treaty this year.

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Liechtenstein Extends Global Tax Treaty Network 28/11/2012
The Liechtenstein tax administration has recently negotiated and initialed in Vaduz a double taxation agreement in the area of taxes on income and on wealth with the Kingdom of Bahrain, the latest in a succession of tax agreements signed by the Principality.

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South Africa, Seychelles DTA Protocol Comes Into Effect 13/6/2012
It has been announced that the protocol to the existing double taxation agreement between South Africa and the Seychelles has been ratified and went into effect on May 15, 2012.

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South Africa Loses CGT Exit Charge Appeal 11/5/2012
The South African Revenue Service has lost its Supreme Court appeal on a case concerning the capital gains tax that it said should be applied on a deemed disposal when a taxpayer becomes non-resident.

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South Africa Provides Ruling On Taxes Within DTAs 20/9/2011
The Legal and Policy Division of the South African Revenue Service has issued a Binding General Ruling that identifies the taxes which constitute taxes on income, or substantially similar taxes, for the purposes of South Africa’s double tax agreements.

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South Africa Looks At Headquarters Company Regime 14/9/2011
While, last year, the National Treasury proposed a new initiative, intended to make South Africa a more attractive base for investment into other African countries by both domestic and foreign investors, taxpayers have raised concerns over the approach of the South African Revenue Service to its headquarters company tax regime.

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Portugal Begins New DTA Negotiations 21/6/2011
The Portuguese government is seeking to expand its tax treaty network, beginning negotiations with three new countries over the last month: Peru, Gabon and Senegal.

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SARS Issues Three-Year Strategic Plan 3/6/2011
Oupa Magashula, Commissioner of the South African Revenue Service, has presented its Strategic Plan for the fiscal years from 2011-12 to 2013-14, expressing his confidence that the Plan provides the blueprint for the continuous compliance growth and sustained revenue realisation, which will be necessary to support economic development in the country.

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South Africa, Kenya Sign DTA 30/11/2010
South Africa’s Deputy President, Kgalema Motlanthe (pictured), and Kenya’s Vice President, Kalonzo Musyoka, have overseen the signing of a bilateral double taxation agreement between their two countries, on the occasion of the former’s visit to Kenya.

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UK, South Africa Amend Double Tax Treaty 17/11/2010
The UK tax authority, HM Revenue and Customs has announced the signing of a protocol to the convention for the avoidance of double taxation with South Africa.

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Argentina Catches Up On Tax Agreements 3/11/2010
The head of Argentina's Federal Administration of Public Revenue, Ricardo Echegaray has announced the signing of tax information exchange agreements with Russia, Italy and France as part of its strategy to crack down on tax evasion.

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South Africa's DTAs With Mexico, Rwanda Become Effective 1/9/2010
The bilateral double taxation agreements completed by South Africa with Mexico and Rwanda have both been passed by parliament and entered into force recently, the South African Revenue Service announced on August 31.

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South Africa And Ireland Update DTA 22/3/2010
In Cape Town, Ireland’s Minister of State for Overseas Development, Peter Power, and South Africa’s Minister of Finance, Pravin Gordhan, have signed a protocol updating the existing double taxation agreement between the two countries.

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Hong Kong Property Taxes Reviewed 16/3/2010
Hong Kong’s Financial Secretary, John C Tsang, made the traditional post-budget speech at the Joint Business Community Luncheon on March 12 and, in particular, reviewed the tax measures taken to increase the transaction cost of property speculation so as to reduce the risk of a property bubble being created.

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NZ Emissions 'Tax' Attacked 15/3/2010
The ACT New Zealand Party, a member of the country’s present coalition government, has continued its opposition to New Zealand’s new carbon emissions trading scheme, calling it a tax that will increase inflation in the economy.

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Orascom Loses Algerian Tax Appeal 12/3/2010
Egyptian telecom company, Orascom Telecom, has announced that its Algerian subsidiary, Orascom Telecom Algérie, has received a rejection to its appeal, made in December last year, against the notice for taxes and penalties it had received from the Algerian tax authorities the month previously.

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