A Canadian resident (being a natural person in the process of applying for a RSA work VISA) performs services relating to debtors and creditors management to a RSA resident company. These services are performed remotely from Canada and not physically within.
Important:
This answer is based on tax law for the tax year ending 28 February 2020.
Answer:
Whilst our service is limited to guidance only, we agree that a receipt or accrual in respect of services rendered by a person not resident in the RSA and where the source of the services is not in the RSA will not be gross income in the RSA.
The agreement between the RSA and Canada deals with this in article 15 (or possibly article 13 – we don’t know what the nature of the services are, i.e. independent or not). From the facts presented, it also doesn’t appear that the person concerned has a "permanent establishment" in the RSA, were rendering the service in the RSA or has a fixed base here.