An analysis of South Africa's tax treaties shows that when South Africa concludes treaties with developed, capital-exporting countries from which South Africa seeks to attract investment, South Africa cedes its taxing rights to those countries. The analysis also shows, however, that South Africa cedes its taxing rights to developing countries in which South African businesses are more likely to invest than the other way around. This article examines this aspect of South Africa's tax treaties and looks for answers to this policy.