Benjamin is 51 years old, lives in America, and is a non-resident for South African income tax purposes. Benjamin has never been to South Africa. Benjamin granted a loan to his cousins construction company, Build-it Limited. Build-it Limited does construction work in South Africa, and the companys place of effective management is in America. Interest to the value of R130 000 on this loan accrued to Benjamin for the 2022 year of assessment.

REQUIRED: Discuss the South African tax consequences/treatment of the interest on the loan for the 2022 year of assessment in terms of South African Income Tax legislation. Your answer should consider the normal tax as well as possible withholding tax consequences for Benjamin.