Moosa, FareedJulius, Leonardo2026-09-182026-09-182025-12-12https://hdl.handle.net/10566/25443This study critically evaluates South Africa’s Double Taxation Agreements with Saudi Arabia and the United Arab Emirates, assessing their effectiveness in achieving an equitable allocation of taxing and tax collection rights. While these treaties successfully mitigate double taxation, the analysis reveals a structural bias favoring residence-state and investment-promoting interest, rooted in OECD model provision, over robust source-state taxing authority. Key treaty features such as tie-breaker residency rules, permanent establishment thresholds and capped withholding taxes on dividends, interest and royalties constrain South Africa's domestic revenue mobilization as a developing capital-importing country. This formal reciprocity masks substantive asymmetries, disproportionately impacting South Africa’s fiscal base while benefiting Gulf states that impose minimal or alternative tax regimes. Judicial confirmation of treaty primacy, alongside administrative limitations and interpretative challenges, further complicates enforcement and revenue protection. By employing doctrinal, comparative, empirical and normative methodologies, the research identifies obstacles in mutual assistance and dispute resolution mechanisms. The study recommends strategic treaty renegotiations, enhanced administrative capacity, taxpayer education and updated cross-border tax collection frameworks aligned with digital economy realities. These measures seek to advance fiscal equity, transparency and sustainable international economic cooperation, contributing to the refinement of international tax law practices.enAllocation of taxing rightsdouble tax agreementdouble taxationmodel tax treatiesresidenceThesis