Where a resident taxpayer derives an amount from a foreign jurisdiction, the amount may be subject to tax in the foreign jurisdiction as well as in South Africa, which, in the absence of a treaty, may potentially lead to double taxation on the same type of income.
To prevent resident taxpayers from being exposed to consequent double taxation, South Africa provides relief to its residents within its own domestic laws, and specifically in terms of s 6quat of the ITA.
Section 6quat broadly makes provision for a rebate or
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