South African Supreme Court of Appeal Confirms Application of Protocol to a Tax Treaty to a Period before Signature Date
Journal
Country
South Africa
Published Date
Issue
Bulletin for International Taxation 2016 (Volume 70), No. 4
Document
The author, in this article, considers the implications of the recent Supreme Court of Appeal of South Africa decision in Krok and Another (2015), in which the Court confirmed the retroactive application of a protocol to a tax treaty to matters that arose before the protocol was concluded.