The taxpayer recently moved to Canada. He receives income from a South African Trust. He paid the South African Tax, but recently had to include it into his Canadian Tax return and it looks like it's being tax double.
Important:
This answer is based on tax law for the tax year ending 28 February 2020.
Answer:
We assumed from the information provided that the individual is a person who is deemed to be exclusively a resident of Canada for purposes of the application of any agreement entered into between the governments of the RSA and Canada for the avoidance of double taxation.
The agreement deals with trust-income in article 21 and the following may be specifically relevant:
“Where such income is income from an estate or a trust, other than a trust to which contributions were deductible, the tax so charged shall, provided that the income is taxable in the Contracting State in which the beneficial owner is a resident, not exceed 15 per cent of the gross amount of the income.”
We can’t comment on the Canadian tax or the relief provided for foreign tax credits.
You are correct that the RSA has a right to tax (article 21(2)). A credit is given for the tax paid in Canada – under section 6quat.