Broader application of the withholding tax on immovable property disposed of by non-residents is envisaged. 

It is proposed that the definition of "immovable property" that is subject to withholding tax be aligned with the definition contained in Article 6(2) of the OECD's model treaty, which includes, "property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources".  Some of these inclusions will extend beyond what is regarded as "immovable property" in terms of South African law and what is currently subject to the withholding tax