Thando Jones lives in Johannesburg. He owns a house in Randburg, where his family resides. He visits Cape Town at least four times a month on business.He stays over in Cape Town for at least two nights per visit. Thando's wife and daughter are sole beneficiaries of the Jones family trust. The Trust owns Sami Pty Ltd. The latter company purchased a house in Bellville, close to Cape Town, to operate as a guest house. Thando's stays at Sami Pty Ltd's guest house during his visit to Cape Town. A market related rental is paid by Concept Ltd, in which Thando is the director and has a 60% shareholding. Concept Ltd's head office is located in Cape Town.

You are required to discuss whether or not the provision to 80L apply to the rental paid by Concept Ltd to Thando Pty Ltd.