Answer ALL the questions in this section.

QUESTION $1$

$1\mathrm{.}1$ Benni is a Spanish citizen who is ordinarily a resident in Spain. During a work trip in $2018$ and $2019,$ he

was in South Africa from $3$ May $2018$ until $15$ February $2019.$ He enjoyed his stay in South Africa and visited

again from $1$ June $2020$ to $31$ December $2020.$ During November $2021$ and December $2021,$ Benni again

visited South Africa for eight weeks. During $2022,$ he visited South Africa once more, from $1$ October $2022$ to

$31$ December $2022$ for $92$ days. He also visited South Africa again in $2023$ from $01$ October $2023$ to $31$

December $2023.$

$1\mathrm{.}2$ Dumisani uses street vendors to sell pirated versions of well$-$known DVD$\text{'}$s to the general public.

His income from these activities amounted to R$110000$ for the $2024$ year of assessment.

REQUIRED:

Discuss in detail whether the above persons will be subject to normal tax in South Africa for the $2024$ year of

assessment.