Page 81 - P6 Slide Taxation - Lecture Day 7 - Various Topics

Example

• Inventeur Ltd, a Mauritian tax resident company,

developed intellectual property and re g istered a

patent in Mauritius. It makes its intellectual

property available to Production (Pty) Ltd, a

South African company. Production (Pty) Ltd uses

the patented technology in its manufacturing

business in South Africa and pays Inventeur Ltd a

usage-based royalty. Discuss the source of the

royalty income received by Inventeur Ltd from

Production (Pty) Ltd.

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