I sincerely hope Kenny is right, but because it is an amendment to the current tax law, nobody knows for sure without seeing the draft legislation. I have been told the complete opposite by tax guys so it is a matter of opinion. However, this is what is in the Budget 2017 documents available on the SA treasury website:
" Amending foreign employment income-tax exemption in respect of South African residents
Currently, if a South African resident works in a foreign country for more than 183 days a year, foreign employment income earned is exempt from tax, subject to certain conditions. This exemption is for employees of private-sector companies. In terms of the residence-based system of taxation, South African residents are taxed on their worldwide income. However, this exemption on foreign employment income appears excessively generous. If a resident works in a foreign country for more than 183 days with no tax payable in the foreign country, that foreign employment income will benefit from double non-taxation. It is proposed that this exemption be adjusted so that foreign employment income will only be exempt from tax if it is subject to tax in the foreign country."