Janet Dube $($currently aged $35$ and single with no dependents$)$ emigrated from South Africa

to Dubai on $1$ March $2018.$ Janet 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, Janet has fully integrated into her life in Dubai.

Despite her relocation, Janet 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 Janet$$s stays in South Africa for each year of

assessment since her emigration are as follows:

$$ In $2019,$ she spent $164$ days in the Republic.

$$ In $2020,108$ days were spent visiting family.

$$ The $2021$ year of assessment saw her in South Africa for $155$ days.

$$ In $2022,$ Janet stayed for $102$ days.

$$ In $2023,$ she spent $133$ days in South Africa.

$$ Most recently, she spent $101$ days in South Africa in $2024.$

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

characterised by the following:

A salary of R$750000($rand equivalent$)$ accrued from her teaching position in Dubai for the

$2024$ year of assessment. Notably, Janet had signed her employment contract in Durban, a

city in South Africa before moving to Dubai.

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

This property, deeply tied to her family's heritage, yielded total rentals of R$186800$ for the

$2024$ year of assessment. The cost of generating these rentals for the $2024$ year of

assessment were: R$68700$ for water and electricity, R$11500$ for cleaning services, R$15000$

for security and R$25000$ for a new wall that had to be erected to add an extra layer of security.

Janet 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$41750$ for the $2024$ year of assessment.

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

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

dividend incomes are deposited, generated R$24800$ in interest for the $2024$ year of

assessment.

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

a non$-$resident bank for South African tax purposes. This account, into which her monthly salary is deposited, earned her interest of R$24500($rand equivalent$)$ for the $2024$ year of

assessment.

Required:

$1\mathrm{.}1$ Discuss whether Janet is 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.

$1\mathrm{.}2$ Assuming that Janet 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 as gross income

for South African income tax purposes. You need to also discuss the costs of generating the

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

Dubai.