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In terms of section 108(2) of the Income Tax Act, 1962 (Act No 58 of 1962), read in conjunction with section 231(4) of the constitution of the Republic of South Africa, 1996 (Act No 108 of 1996), it is hereby notified that the Protocol amending the agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income set out in the schedule to this Notice has been entered into with the Government of the Republic of the Seychelles and has been approved by Parliament in terms of section 231(2) of the Constitution. It is further notified in terms of paragraph 1 of Article XV of the Agreement that the date of entry into force is 15 May 2012.