Page 102 - P6 Slide Taxation - Lecture Day 7 - Various Topics

Rebate for foreign tax

Amounts that qualify for the rebate
• A resident may deduct a rebate when determining its normal tax payable where that resident’s
taxable income for the year of assessment includes certain foreign sourced amounts that are
subject to tax in South Africa (s 6 quat (1)).
• These foreign sourced amounts, which may potentially also have been subject to foreign tax, are
• income received by or accrued to the resident from a source outside South Africa (see 21.3)
• taxable capital gain from the disposal of an asset that has a source outside South Africa (see
21.3.4)
• any of the following amounts that are deemed to have accrued to or been received by the

resident:
 a foreign sourced amount attributed to the resident as a result of a donation, settlement or other
disposition by the resident (s 7 – see chapter 24)
 a foreign sourced capital gain attributed to the resident as a result of a donation, settlement or other
disposition by the resident or from a distribution by a trust (paras 68 to 72 and 80 of the Eighth Schedule –
see chapter 24)
 a distribution of foreign sourced income or capital gain by a non-resident trust to the resident in any year
following the year during which the amount accrued to the foreign trust (s 25BA and par 80(3) of the Eighth
Schedule – see chapter 24)
• a proportional amount of net income of a controlled foreign company in relation to the resident
(see 21.7)

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