Double Taxation Relief Manual: Guidance by country: South Africa: Source of income
For periods from 1 April 2003 (CT) and 6 April 2003 (IT) for the purposes of giving credit profits, income and capital gains that may be taxed in South Africa are deemed to be sourced there. See Article 21(3) of the treaty.
Under the previous treaty, remuneration for personal (including professional) services performed in South Africa were deemed to be income from sources in South Africa (Article 22(4)). Interest was deemed to arise in the country of which the payer was a resident.