Section 10(1)(h) of ITA

(h)     any amount of interest which is received by or accrues to any person that is not a resident, unless-

[Words preceding subparagraph (i) substituted by section 16 of Act 17 of 2017 effective on 18 December 2017]

(i)      that person is a natural person who was physically present in the Republic for a period exceeding 183 days in aggregate during the twelve-month period preceding the date on which the interest is received by or accrues to that person; or

[Subparagraph (i) substituted by section 22 of Act 23 of 2018 effective on 17 January 2019]

(ii)     the debt from which the interest arises is effectively connected to a permanent establishment of that person in the Republic;