IN a Binding Private Ruling, the South African Revenue Service (SARS)
held that “registration of the External Company will not create a permanent
establishment for the Applicant in South Africa”. The Ruling is subject the
conditions and assumptions that –
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The Applicant's place of effective management will be located in the specified
foreign country in which the Applicant is a resident;
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The Applicant will not have any employees or conduct any business activities in
South Africa, other than the maintenance of its External Company status for
exchange control purposes; and
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The Applicant will not have a dependent agent operating on its behalf in South
Africa.
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