Changes are being proposed to the foreign earnings exemption which may potentially affect South African tax liability in relation to foreign-earned remuneration. The exemption currently applies where a South African resident renders services outside South Africa. However, the scope of the exemption may be limited. Employers planning international assignments of employees should monitor developments in this area.
The revised amendments contained in the Revenue Laws Amendment Act 2008 make two main changes to the existing regime in regard to the definitions of a 'labour broker' and a 'personal service provider'. The definition of a 'labour broker' will now apply only to individuals who are sole proprietors carrying on a labour broking business.