Page 12 - P6 Slide Taxation - Lecture Day 5 - Foreign Exchange
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22.2.1. PERSONS SUBJECT TO PROVISIONS OF s 24I?
→ S 24I(2) determines that s 24I is applicable to any:
a) company
b) trust carrying on a trade
c) NP who holds a unit of currency or debt as TS
d) NP or trust that is a party to a FEC or a FCOC
S 24I is not applicable to non-residents,
except a CFC (refer s 9D – Silke Chapter 19)
unless
the exchange item is attributable to a permanent FOREIGNER
establishment in SA.
