SECTION A

$100$ MARK

Answer ALL the questions in this section.

QUESTION $1$

$1\mathrm{.}1$ Berri is a Spanish citzen who is ordracly a resibent in Spain. Durng a work trp in $2018$ and $2019,$ he

$(20$ Marl

$16$Mar$$

was in South Altica from $3$ May $2018$ umil $15$ February $2019.$ He empyed his stay in South Afrca and visied again from $1$ Jure $20201031$ December $2020.$ During November $2021$ and December $2021,$ Benri again visited South Africa for echt weeks. During $2002,$ he visited South Africa once more. I'om $1$ Oclober $2022$ to $31$ December $2002$ for $92$ days. He also visited South Africa again in $2023$ from $01$ Oclober $2003$ to $31$ Decerber $2023$

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

$(4.$Mar

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

REQUIRED:

Discuss in detal whether the above persons wi be subpct to normal tax in Sowh Alica for the $2024$ year of assessment.