The South African Revenue Service has recently published a draft interpretation note providing guidance on the interpretation and application of the term "place of effective management" in determining the tax residence of a company and any other entity or body of persons that is not a natural person.
According to the South Africa Income Tax Act No. 58 of 1962, a resident means any person (other than a natural person) which is incorporated, established or formed in the (South African) Republi…