Section 9(4) of the South African Income Tax Act deals with the taxation of income earned by non-residents from services rendered or goods supplied in South Africa. It states that such income will be subject to tax in South Africa if the non-resident person has a fixed place of business in South Africa through which the services are rendered or goods are supplied. If the non-resident person does not have a fixed place of business in South Africa, the income will not be subject to tax in South Africa, unless the services were rendered or goods were supplied in the country for a period that exceeds 183 days in aggregate during a 12-month period.
