“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 of “resident of the Republic” amended by section 64(b) of Act 59 of 2000 and substituted by section 45(1) of Act 42 of 2024 effective on 1 January, 2025]