QROPS Advice: Taxation of ‘Non-Residents’ Living in South Africa

In general, foreign workers rendering services in South Africa on short term contracts would not become ordinarily resident and, depending on the period of the assignment, may also avoid becoming residents under the physical presence test.
Individuals deemed to be non-residents of South Africa for tax purposes will only be taxed on their South African sourced income and are entitled to limited deductions. Employment income earned by non-residents from offering their services in South Africa is taxable in South Africa irrespective of where, when and by whom it is paid. In contrast, earnings from services offered outside South Africa will not be taxable, even if it is paid by a South African employer.
South African sourced dividend income in the hands of non-resident individuals is exempt from tax. Interest derived by a nonresident is also exempt if they do not have a permanent establishment in the country and were not in the country for at least 183 days during the tax year. Non-residents are subject to a final withholding tax of 12% of the gross amount of royalties arising from intellectual property in South Africa. Rental income is generally fully taxable if derived from a property located in South Africa.
In general, non residents are only taxed on capital gains in the disposal or deemed disposal of immovable property or rights in immovable property situated in South Africa. CGT is levied at normal income tax rates on the first 25% of the gain realised by the individual.
Only property or deemed property situated in South Africa belonging to a deceased non-resident person is subject to inheritance tax.

http://www.ailo.org/common/externalPage.asp?intURL=/publications/default.asp&extURL=/downloads/South_Africa_2009.pdf