Page 3 - Non-residence taxation

Non-residence Taxation

Source

• The term 'source' is not separately defined in the Act,

which is probably due to the fact that it would be

impossible for the legislature to define the source of all

types of income which a taxpayer may earn. Therefore, in

determining the source of a receipt or accrual, it is

necessary to consider court decisions on the subject,

however, it is important to keep in mind that the

determination of source is a factual question that must be

determined in light of all the surrounding circumstances.

In the case of services rendered in an employment

context, it is a generally accepted principle that the source

of income would be the place where the activity leading to

the generation of income is physically being conducted.

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