Sinbad
Honorary Master
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- Jun 5, 2006
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You're right, I got it completely wrongNot sure about the first part and have scheduled a call with my account/tax specialist on Thursday to discuss (they are South African and deal extensively with cross border tax stuff).
I've asked them before about the "expat tax" and the UK/SA DTA nullifies it completely. It's only applicable for countries without a DTA and those where the DTA does not grant full taxing rights to the other state.
It is taxation based on residence regardless of source.
I found this in the DTA though:
Subject to the provisions of Articles 15, 17 and 18 of this Convention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
I don't know what the definition of "exercised" is in this case - it may be relevant.
