The South African Revenue Service has recently published a draft interpretation note providing guidance on the interpretation and application of the term "place of effective management" in determining the tax residence of a company and any other entity or body of persons that is not a natural person. According to the South Africa Income Tax Act No. 58 of 1962, a resident means any person (other than a natural person) which is incorporated, established or formed in the (South African) Republic or which has its place of effective management in the (South African) Republic. Although the Tax Act does not...