On 3 November 2015, the South African Revenue Service published Interpretation Note 6 (Issue 2) - Resident: Place of Effective Management (Companies), which is an update of the original Note published in 2002.The Note provides guidance on the interpretation and application of the term “place of effective management” in determining the tax residence of a company.
The Note defines a company's place of effective management as the place where key management and commercial decisions that are nece…