Protocol to the 1947 Treaty (1952)

Protocol (1950) amending Transfer Tax Agreement (1947)

PROTOCOL SUPPLEMENTING THE CONVENTION FOR THE AVOIDANCE OF DOUBLE TAXATION AND FOR ESTABLISHING RULES OF RECIPROCAL ADMINISTRATIVE ASSISTANCE WITH RESPECT TO TAXES ON THE ESTATES OF DECEASED PERSONS, SIGNED AT CAPE TOWN ON 10 APRIL 1947. SIGNED AT PRETORIA, ON 14 JULY 1950

The Government of the United States of America and the Government of the Union of South Africa,

Desiring to conclude a protocol supplementing the Convention for the avoidance of double taxation and for establishing rules of reciprocal administrative ssistance with respect to taxes on the estates of deceased persons which was signed at Cape Town on April 10, 1947,

Have agreed as follows:-

Article I

Article VIII of the Convention signed April 10, 1947, relating to taxes on the estates of deceased persons, is amended by deleting paragraph (4) and substituting the following:-

“(4) The assistance provided for in this Article shall not be accorded in respect of any citizen or national, or the estate of any citizen or national, of the Contracting Party to which application is made except where such citizen or national or estate is entitled to the allowance of a credit under Article V of the present Convention.”

Article II

1. This protocol shall be ratified and the instruments of ratification thereof shall be exchanged at Washington as soon as possible.

2. This protocol shall become effective and continue effective in accordance with Article XIII of the Convention of April 10, 1947, and, in the event of termination of such Convention, shall terminate simultaneously with such Convention.

IN WITNESS WHEREOF the undersigned plenipotentiaries, being authorized thereto by their respective Governments, have signed this protocol and have affixed thereto their seals.

DONE in duplicate, in the English and Afrikaans languages, at Pretoria this the fourteenth day of July, 1950.

For the Government of the United States of America:
Bernard C. Connelly
Chargé d’Affaires ad interim of the United States of America

For the Government of the Union of South Africa:
P. O. Sauer
Minister of Transport of the Union of South Africa