Ms Lerato was born in the United Kingdom (UK) and spends most of her time in the UK. She regularly goes for holidays in Mauritius, and she often visits South Africa. The following facts are relevant:

- She is a member of the UK House of Commons (equivalent to national parliament);

- She spends 185 days in South Africa and has done this for the past 10 years;

- She spends 140 days in the UK and has done this for the past 10 years;

- She spends 40 days a year in Mauritius and has done this for the past 10 years;

- She has a flat in London, a large seaside villa in Mauritius (with a yacht moored there) and a house in South Africa;

- She has a partner who permanently lives in South Africa;

- She is a director of Consult UK Ltd, and earns a salary from this company for work done in London;

- She is a director in a South African Coal company, from which she receives dividends;

- She is a member of the South African Golf Club;

- All her children are adults who live in the UK;

- All her pets, her favourite oil paintings, her ancestral home and her motor car collection are in the UK;

- She does not hold a South African Identity Card or a South African drivers license;

- The main source of her income other than as stated above is interest and dividends from investments in the Cayman Islands.

South Africa and the UK tax their residents on a worldwide basis and their non- residents on a source basis. With reference to relevant case law, and statutes, advise Ms Lerato regarding her tax liability in South Africa only. In your answer, also determine the income tax consequences of the relevant transactions (income

received, dividends, and interest). Give reasons for your answer. Assume all income was received during the 2022/2023 year of assessment.