QUESTION 1 [30] "Expat tax" will be levied on South Africans working abroad from 1 March 2020. Brian and Brenda are two of your clients working in London, United Kingdom (UK), since 2010. With Brexit that started in February 2020 they are unsure how this will affect their South African Income Tax Affairs. Both Brian and Brenda are citizens of South Africa. They spend about 11 months of each year outside South Africa and visit family and friends for Christmas each year in South Africa. Brian earns R600 000 per year and Brenda R1 500 000 per year. They don't know whether they will return to South Africa permanently in future. They have many questions about this new "expat tax" being introduced in South Africa. Will it apply to them? Will they pay more tax now? How should they pay the expat tax? Should they formally and financially emigrate to the UK? Should they stay South African citizens? What would be the best for their family? They have two children born in the UK aged two and three. Taking all of the above into account, advise Brian and Brenda on the best way to handle their tax affairs in future in order to accommodate "expat tax". In addition to answering their questions stated above, you have to explain what "expat tax" is; how it was introduced in South Africa and the reasons behind it; when it is applicable and when not; how it will affect couples as opposed to individuals; whether any double taxation problems exist and any other aspect you deem fit for your clients to know. You may assume facts in amplification of your answer where reasonably required. (30)