The taxpayer sells overseas tour packages to local schools in the RSA. The local schools pay for the packages in "R" in the RSA. Do these tour packages attract VAT? Technically the service is rendered overseas but to a RSA resident.
According to s11(2)(k) of the VAT Act, if a service is rendered physically outside of S.A, the service will be at 0% VAT.
The residency of the "buyer" has no relevance.