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Question 2 Mia Bennett ( currently aged 3 5 and single with no dependents ) emigrated from South Africa to Dubai on 1 March 2

Question 2
Mia Bennett (currently aged 35 and single with no dependents) emigrated from South Africa
to Dubai on 1 March 2018. Mia 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, Mia has fully integrated into her life in Dubai.
Despite her relocation, Mia 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 Mia's stays in South Africa for each year of assessment
since her emigration are as follows:
In 2019, she spent 24 days in the Republic.
In 2020,98 days were spent visiting family.
The 2021 year of assessment saw her in South Africa for 105 days.
In 2022, Mia stayed for 92 days.
Most recently, in 2023, she spent 103 days in South Africa.
For the year of assessment ending on 28 February 2024, Mia's financial situation is
characterized by the following:
A salary of R640,000(rand equivalent) accrued from her teaching position in Dubai for the
2024 year of assessment. Notably, Mia had signed her employment contract in South Africa
before moving to Dubai.
Several years ago, Mia inherited a rent producing property in Durban from her grandfather.
This property, deeply tied to her family's heritage, yielded total rentals of R138,400 for the
2024 year of assessment.
Mia 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 R21,650 for the 2024 year of assessment.
Understanding the importance of maintaining financial ties to her homeland, Mia holds a
current account with Capital Bank in South Africa. This account, into which her rental anddividend incomes are deposited, generated R11,850 in interest for the 2024 year of
assessment.
In Dubai, Mia manages her living expenses through a bank account with the Bank of Dubai, a
nonresident bank for South African tax purposes. This account, into which her monthly salary
is deposited, earned her interest of R13,500(rand equivalent) for the 2024 year of
assessment.
Required:
Discuss whether Mia is considered to be 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.
Assuming that Leah 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 to be gross
income for South African income tax purposes. You may assume that there is no double
tax agreement between South Africa and Dubai.

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