A leading lung specialist (a SA resident) in private practice in the Republic of South Africa was flown to a Central African State to perform an operation on one of their top ministers. The president (of the African State) sent his private jet to fetch and return the specialist. All his expenses were paid and, although he did not wish to be paid for his services, the government of the African State insisted on paying him the equivalent of R100 000.

REQUIRED:

1. Explain where the source of the income would be. (5)

2. Explain with reasons whether the lung specialist will be taxed on the amount in the Republic of South Africa. (4)