Section 10(1)(l) of ITA

(l)      the amount of any royalty as defined in section 49A which is received by or accrues to any person that is not a resident, unless-

(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 amount is received by or accrues to that person; or

(ii)     the intellectual property or the knowledge or information in respect of which that royalty is paid is effectively connected with a permanent establishment of that person in the Republic;

[Paragraph (l) deleted by section 10 of Act 101 of 90. inserted by section 13 of Act 59 of 2000 and substituted by section 19 of Act 22 of 2012 and section 14 of Act 43 of 2014 effective on 1 January 2015]