AdrieSpaans, ordinarily resident in the Netherlands, designed a model pattern that was used to teach the art of tailoring. She had developed this pattern in the Netherlands. Due to its popularity in the Netherlands she visited South Africa and marketed her product here. In the current year of assessment Adrie received payments amounting to R120 000 from various design schools in South Africa that used the pattern as a teaching aid.

Required: Discuss whether the R120 000 received would be taxed in South Africa or not, indicating the source of the income with reference to the Income Tax Act or common law principles as appropriate. (7)