Question 3 (23 marks) Andrew Noel (Andrew) is a 67-year-old famous stand-up comedian. He emigrated from South Africa to the United States of America (USA) on 15 March 2020. Andrew is not married and does not have children. Andrew does not carry on a business through a permanent establishment in South Africa. He has also never visited South Africa since leaving in March 2020 due to the lockdown restrictions. The following information relates to Andrew for his 2021 year of assessment: 1. Andrew received R200 000 for a comedy tour he conducted in Botswana. Andrew was in Botswana from 6 to10 March 2020. 2. He presented a corporate conference in Potchefstroom on 5 March 2020 and submitted an invoice of R55 000 on the same day for presenting at the conference. The organisers of the conference only paid Andrew on 31 October 2020. 3. Andrew owns the following properties 3.1 A holiday home in Magaliesberg (South Africa). Andrew wanted the house to be sold as soon as possible before leaving South Africa and paid R15 000 on

10 February 2020 to a real estate agent to actively market the house. He sold the house for R3 500 000 to a non-connected person on 10 March 2020. Andrew originally purchased the house on 29 August 2017 for R2 170 000. 3.2 A block of flats situated in Fourways, South Africa from which rental income of R576 000 accrued to him evenly during the 2021 year of assessment. The block of flats is let to non-connected persons. 4. During October 2018 Andrew published a book with a media house in Sandton. On 31 January 2021, Andrew earned 20% of the annual net receipts made by the media house amounting to R72 000. 5. Andrews book won a South African Literary award valued at R120 000 which was awarded to him on 3 November 2020. 6. Andrews investor tax certificate (IT3b) reflected that he earned interest of R46 850 during his 2021 year of assessment. Andrew made the investment in 2015 at South African bank. R25 850 of the interest was paid to Andrew on 31 July 2020 and R21 000 was paid to him on 31 January 2021. 7. A South African based streaming service signed a deal with Andrew on 29 June 2020 to exclusively air one of his stand-up comedy shows for a period of three years. The comedy show was recorded when Andrew was still a South African resident in 2019 and will only be aired in the European countries. The streaming service paid Andrew a once-off fee of R14 000 000 on 1 July 2020 and R1 210 000 on 20 February 2021. The R1 210 000 represents an agreed percentage of the streaming revenue generated by the comedy show. 8. Andrew made provisional tax payments of R312 235 in respect of his 2021 year of assessment. REQUIRED: Calculate Andrews normal tax payable in South Africa for his 2021 year of assessment. Clearly show the total gross income and exempt income. Show all workings. Where any amount is excluded, this must be clearly indicated supported with a brief reason. Ignore any effects of double taxation agreements. References to legislation are not required.