"resident of the Republic"
means—
(a) | a resident as defined in section 1 of the Income Tax Act, other than a person that— |
(i) | is a ‘resident’ solely as a result of having its place of effective management in the Republic as referred to in paragraph (b) of that definition; and |
(ii) | does not carry on an enterprise in the Republic; or |
(b) | any other person or any other company to the extent that such person or company carries on in the Republic any enterprise or other activity and has a fixed or permanent place in the Republic relating to such enterprise or other activity; |
[Definition substituted by section 45(1) of the Taxation Laws Amendment Act 42 of 2024, Notice No. 5736, GG51826, dated 24 December 2024 - comes into operation on 1 January 2025 (section 45(2))]