Direct Taxation of E-Commerce in South Africa

The term “” is a broad concept that covers any commercial transaction effected via electronic means, The concepts of ‘source’ and ‘residence’ in the context of income tax legislation are key to determining the jurisdiction in which income is taxable. The application of traditional concepts to this determination in South Africa has been is less than successful with regard to e-commerce transactions.

The following questions have been addressed in this article:

What is the concept of ‘source’ with respect to E-commerce in South Africa?
What is the concept of ‘residence of a company’ with regard to e-commerce?


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