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Manufacturer Co Ltd is incorporated and managed in South Africa. It wishes to sell its products in Mauritius. Manufacturer Co Ltd appoints Jacob as its

Manufacturer Co Ltd is incorporated and managed in South Africa. It wishes to sell its products in Mauritius. Manufacturer Co Ltd appoints Jacob as its agent in Mauritius. Previously he has worked as an agent for various foreign companies, but since two years he spends all his time on the business of Manufacturer Co Ltd. Jacob solicits orders from customers and forwards them by fax to the head office of Manufacturer Co Ltd for action. The clerical assistant of the Sales Manager in head office has instructions to follow all recommendations of Jacob. Orders are filled by shipment direct from head office to the person who placed the orders. Required: Does Manufacturer Co Ltd have a permanent establishment in Mauritius? If so, what profits are taxable there? (5 marks)

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