The Government of the Republic of South Africa and the Government of the Republic of Zrmbabwe;
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:
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions, irrespective of the manner in which they are levied.
2. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property.
3. The existing taxes to which this Agreement shall apply are:
(a) in South Africa:
(i) the normal tax;
(ii) the dividends tax;
(iii) the withholding tax on royalties;
(iv) the tax on foreign entertainers and sportspersons; and
(v) the withholding tax on interest; (hereinafter relerred to as "South African tax");
(b) in Zimbabwe:
(i) the income tax;
(ii) the non-resident shareholders' tax;
(iii) the non-residents' tax on fees;
(iv) the non-residents' tax on royalties;
(v) the capital gains tax; and
(vi) the residents' tax on interest; (hereinafter referred to as "Zimbabwean tax").
The Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their respective taxation laws.