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The taxation of amounts received by or that accrue to non-residents will generally be subject to tax in South Africa, subject to the application of the Double Tax Agreement. The reason for this is simply that the amount will be considered to be from a South African source and we do not have a domestic de minimis rule as to how many days a natural person can work in South Africa before they will be subject to income tax.

Amounts from a South African source fall within a non-resident's gross income and, as discussed, will fall within the ambit of remuneration if not specifically exempt under the ITA. We have a hybrid system of sources where certain rules are codified, whereas others are prescribed by the common law.

We note the source rules for various sources of income that may be earned by individual taxpayers below:

1. Ìý

   •ÌýÌýÌýÌý Dividends – dividends declared by a South African resident company are from a South African source (s 9(2)(a)).

2. Ìý

   •ÌýÌýÌýÌý Interest – interest