- 1.It is understood that nothing in this Article shall prevent South Africa from imposing on the profits attributable to a permanent establishment in South Africa of a company – which is a resident of the Netherlands – a tax at a rate which does not exceed the rate of normal tax on companies by more than five percentage points.
- 2.It is further understood that the provision of paragraph 1 shall only apply as long as permanent establishments of companies which are not residents of South Africa are not liable to the secondary tax on companies.
- 3.It is furthermore understood that the provision of paragraph 1 shall no longer apply if South Africa were to abolish the secondary tax on companies or if it were to levy this tax on residents of South Africa at a rate of less than five percentage points.
