1. Andy was employed by ABC Ltd, a company incorporated in South Africa for 20 years. During his employment with ABC Limited, he worked in Guernsey for a period of 10 years, and in South Africa for 10 years. During the full tenure of his employment with ABC Ltd, he belonged to a South African pension fund. There is no double tax agreement between South Africa and Guernsey. Andy retired from employment and the pension fund on 28 February 2021. During the 2022/2023 year of assessment, he received compulsory annuity income form a South African insurer, purchased with his retirement interest in the pension fund. Which one of the following statements is correct?

	a.	In terms of the income Tax Act, only the portion of the annuity related to South African service will be taxable in South Africa.
	b.	In terms of the income Tax Act, the annuity income will be fully exempt in South Africa.
	c.	In terms of the income Tax Act, the total annuity income will be taxable in South Africa.
	d.	In terms of the Income Tax Act, the answer to the question whether the annuity income is taxable in South Africa or not, will be dependent on the rules of the pension fund and the terms of Andy's employment contract.
	e.	None of the above

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