Taxation of international executives
There are no special residency considerations. The residency rules that would apply to an individual who is on a long-term assignment would also apply to an individual who is on a short-term assignment. However, it is unlikely that a short-term assignee would trigger tax residency in South Africa.
In cases whereby South Africa has a Double Tax Agreement with the other country/jurisdiction in question. One would need to structure the short time assignment, in a way that would ensure that the individual would be able to meet the requirements of the Double Tax Agreement relief, that is intended for short term assignments, if possible.
All information contained in this publication is summarized by KPMG Services (Pty) Ltd, the South African member firm affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity, based on the South African Income Tax Act 58 of 1962 and subsequent amendments; the Tax Administration Act 28 of 2011; Interpretation Notes and Rulings issued by the South African Revenue Service from time to time; applicable South African and relevant global case law.
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