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Residency - Coggle Diagram
Residency
s31 Transfer Pricing
Primary Adj =Replace the income to what it is supposed to be
Secondary adj =Pay dividend tax (Co.) or Donations tax (NP)
Deducted 120k instead of 50k
Fx Co and Res Company =Connected. 2. Tax benefit is derived
Included 50k in GI instead of 100k
SA Dividends to NR
Article 10 DTA
s10 (1)(k) exemption
s64E WHT at 20%
S9 source of income
SA interest to NR
s50B WHT at 15%
s50D exemption
s9 Source of income
s10 Exemption
Foreign dividends--> fx credit
If fx charged you 15% then SARS will tax 5%
If fx taxed you 11% the SARS will tax 9%
SARS can only tax up to 20%