Page 45 - F6 Slides (CGT,TT,ET AND PT)
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Non-residents
• South African employers may from time to time employ non-residents for short periods.
• When their services are rendered outside South Africa, their income is clearly from a source
outside the Republic and employees’ tax need not be deducted.
• When their services are rendered in the Republic, employees’ tax will have to be deducted,
since the source of their income from remuneration will be in the Republic.
• In certain instances, a double taxation agreement between the Republic and the country of
residence of the employee may relieve an employee of liability to South African tax, in
which event employees’ tax need not be deducted.
• Section 10(1)( c )(v) provides an exemption for salaries paid to any subject of a foreign state
who is temporarily employed in the Republic, provided that the exemption is authorised by
an agreement entered into by the governments of the foreign state and the Republic (see
chapter 5).
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