Inge Eckhoff (aged 30 and not married) is a South African tax resident. Inge resides in Langenhovenpark, Bloemfontein. Inge was employed by Agrico (Pty) Ltd (‘Agrico’), an agricultural supply company, as a credit controller. Agrico is also a SA resident for tax purposes. Due to the impact of COVID19 on the South African economy, Agrico retrenched a number of its employees to reduce its overall expenditure. Inge was, therefore, retrenched with effect from 31 July 2020 (her last day of employment). 

On 1 August 2019, Inge inherited a 1-bedroom studio apartment in Berlin (Germany) from her late grandmother. Her grandmother was ordinarily resident in Germany. She resided in this studio apartment until her death. Inge was able to let (∴ rent out or lease) the studio apartment that she inherited. As Inge was not able to secure any other employment after her retrenchment, she decided to sell the studio apartment on 1 September 2020 to obtain funds to start her own German delicatessen in Bloemfontein (a delicatessen is a “retail establishment that sells a selection of fine, exotic, or foreign prepared foods” (https://en.wikipedia.org/wiki/Delicatessen)). She always dreamt of owning her own delicattesen, where she could sell the delicacies and food unique to her grandmother’s roots. 

As Inge wanted to sell the studio apartment in a hurry, she advertised the studio apartment in German newspapers, on German property websites as well as on social media sites. On 30 September 2020, she sold the studio apartment (as is) for the equivalent of R1 800 000 (correctly converted to rand). This resulted in large profit. Discuss whether the amount of R1 800 000 earned from the sale of the 1-bedroom studio apartment in Berlin (Germany) by Inge Eckhoff on 30 September 2020 is of a capital or revenue nature for the year of assessment ended 28 February 2021. 

Support your discussion with references to relevant case law. Your discussion should include a maximum of four (4) objective factors. Communication mark: 

Use of IPAC method to structure answer.