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National Rentals CC trades as an agent for property owners who let their properties to tenants. Its activities include collecting rentals and maintaining some properties

National Rentals CC trades as an agent for property owners who let their properties to tenants. Its activities include collecting rentals and maintaining some properties situated offshore. One of the properties National Rentals CC manages is a block of flats situated in Malta. The separate units within this property belong to different persons. The following persons each earned rentals the equivalent of R85 000 during the 2021 year of assessment from this block of flats. Each person is concerned that he may be liable for normal tax in South Africa. REQUIRED: Discuss the gross income requirements as well as the physical presence test. (10 Marks) Walter Wentworth (5 Marks) Walter Wentworth lives in South Africa. He was on holiday in Australia for the last 92 days of the 2021 year of assessment. Venicia Ltd (5 Marks) Venicia Ltd is incorporated in South Africa. It carries on business in Europe. Its place of effective management is in Lucerne, Switzerland. Its year of assessment ends on the last day of February. REQUIRED: Indicate if the above persons will be subject to normal tax in South Africa for the 2021 year of assessment. (Ignore the provisions of a double tax agreement that may be applicable.)

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