Question $2[24]$

Mia Bennett $($currently aged $35$ and single with no dependents$)$ emigrated from South Africa

to Dubai on $1$ March $2018.$ Mia is a dedicated primary school teacher who was offered a

permanent position at an international school in Dubai. With no intention of returning to South

Africa to reside permanently, Mia has fully integrated into her life in Dubai.

Despite her relocation, Mia maintains strong ties to South Africa. Every year since her

emigration, she visits South Africa to reconnect with her family, who all still reside in the

Republic. During her visits, she stays with her parents, enjoying the warmth and familiarity of

her childhood home. The duration of Mia$$s stays in South Africa for each year of assessment

since her emigration are as follows:

$$ In $2019,$ she spent $24$ days in the Republic.

$$ In $2020,98$ days were spent visiting family.

$$ The $2021$ year of assessment saw her in South Africa for $105$ days.

$$ In $2022,$ Mia stayed for $92$ days.

$$ Most recently, in $2023,$ she spent $103$ days in South Africa.

For the year of assessment ending on $28$ February $2024,$ Mia$$s financial situation is

characterized by the following:

A salary of R$640,000($rand equivalent$)$ accrued from her teaching position in Dubai for the

$2024$ year of assessment. Notably, Mia had signed her employment contract in South Africa

before moving to Dubai.

Several years ago, Mia inherited a rent producing property in Durban from her grandfather.

This property, deeply tied to her family's heritage, yielded total rentals of R$138,400$ for the

$2024$ year of assessment.

Mia has invested in the South African economy by owning shares in public companies listed

on the Johannesburg Stock Exchange. These investments paid off, yielding gross dividends

of R$21,650$ for the $2024$ year of assessment.

Understanding the importance of maintaining financial ties to her homeland, Mia holds a

current account with Capital Bank in South Africa. This account, into which her rental and

dividend incomes are deposited, generated R$11,850$ in interest for the $2024$ year of

assessment.

In Dubai, Mia manages her living expenses through a bank account with the Bank of Dubai, a

nonresident bank for South African tax purposes. This account, into which her monthly salary

is deposited, earned her interest of R$13,500($rand equivalent$)$ for the $2024$ year of

assessment.

Required:

$1.$ Discuss whether Mia is considered to be a resident in South Africa for the $2024$ year of

assessment. You may assume that there is no double tax agreement between South Africa

and Dubai. $(11)$

$2.$ Assuming that Leah is not a resident of South Africa, discuss whether the amounts

received by$/$accrued to her for the $2024$ year of assessment will be considered to be gross

income for South African income tax purposes. You may assume that there is no double

tax agreement between South Africa and Dubai. $(13)$