I have a few clients which are pilates working for Air Mauritius and have been doing so for many years. They live abroad. They do come home when their flights bring them here, but all maintain the 183 days of which 60 are continuous. Are the new residence
Important:
This answer is based on tax law for the tax year ending 28 February 2020.
Answer:
We take it you meant pilots working for Air Mauritius and not ‘pilates’ instructors? We also accept that the individuals are in employment.
We also accept that the individuals concerned were not living and working in a treaty country. In other words, individually was not a “person who is deemed to be exclusively a resident of another country for purposes of the application of any agreement entered into between the governments of the Republic and that other country for the avoidance of double taxation”.
The proposed amendments to section 10(1)(o)(ii) of the Income Tax Act, will only become effective on 1 March 2020. It would then only, based on the wording in the Bill before Parliament, apply to the extent to which that remuneration exceeds one million Rand in respect of a year of assessment.