Abstract:
This article analyses the principles for determining the source of
income in South Africa for tax purposes. The fact that South Africa is
increasingly becoming part of the international community, has
resulted in changes in the economic environment. This means that
current legislation is inadequate to prevent the erosion of the South
African tax bases. The South African Revenue Services therefore
introduced new legislation to prevent this loss of income.
In this article the legislation is examined and illustrated in a practical
situation and problems with the application of the various sections are
identified.