Rosa Turner $($aged $48$ and formerly a resident of the Republic$)$ emigrated to France on $1$ March $2017,$

after she was offered a lucrative employment contract in the field of medical research. Rosa is

regarded to be ordinarily resident in France since her emigration.

During the $2024$ year of assessment, Rosa took an extended leave of absence from work to spend a

few months $(122$ days in total$)$ with her aging parents in Cape Town, South Africa. Prior to the $2024$

year of assessment, since her emigration, Rosa spent only the month of December $(31$ days$)$ each year

in South Africa, visiting family and catching up with old friends.

The following information relates to Rosa$$s receipts and accruals for the year of assessment ended

$29$ February $2024($she is not considered to have any $$permanent establishment$$ as defined in section

$1$ of the Income Tax Act, inside or outside the Republic$)$:

$$ A salary of R$2100000($Rand equivalent$)$ from her employment with Medsearch $($an institute for

medical research, resident in France$).$ Rosa$$s research is based at the institute$$s main research

laboratory situated in Paris. She signed her employment contract in South Africa, prior to her

emigration;

$$ Gross rentals of R$600000$ from the letting of her former residence situated in Cape Town, South

Africa;

$$ Gross dividends of R$22150$ from her shareholdings in South African companies listed on the

Johannesburg Stock Exchange $($JSE$).$ None of these companies are regarded as a REIT or a

controlled company, as defined;

$$ Dividends from foreign companies $($companies resident outside South Africa$)$ amounted to

R$38650($Rand equivalent$)$ for the $2024$ year of assessment $$ Rosa does not hold at least $10\%$ of

the total equity shares or voting rights in any of these companies;

$2$

$$ Rosa holds a current account with Third National Bank $($a South African resident bank$),$ into which

the rental income and South African dividend income is deposited. This account yielded interest

of R$37300$ for the $2024$ year of assessment;

$$ Rosa$$s other current account, held with Bank of France $($a non$-$resident for South African tax

purposes$),$ earned the Rand equivalent of R$51800$ in interest for the $2024$ year of assessment. Her

monthly salary is deposited into this bank account. None of the funds in this account are utilised

within the Republic.

Additional information:

Rosa is considering selling her former residence in Cape Town. An estate agent has advised her that

she should update the home by upgrading the interior finishes and adding in automated technological

features as she could realise a much higher selling price. The estate agent is highly successful at selling

homes to high profile buyers in the area and thinks that a modern, automated home meets the needs

of such buyers. These updates would be quite costly but the agent is positive that Rosa will make a

significant profit on the sale and more than recover her costs of the recommended improvements.