Page 63 - P6 Slide Taxation - Lecture Day 7 - Various Topics
P. 63
Source-Statutory source rules
• The source of income can be determined in terms of
statutory source rules or common law established in case
law.
• The Act governs the source of a number of income streams
(s 9). The statutory source rules contained in the Act largely
reflect the source principles applied in tax treaties. These
rules deal mostly with passive income, for example interest
and royalties.
• A number of the statutory source rules refer to the
presence of a permanent establishment in South Africa or
abroad. A taxpayer will have a permanent establishment in
another jurisdiction if it carries on business through a fixed
place situated in that jurisdiction. The concept of
permanent establishment
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