Received this via email from a tax practioner in SA:
Dear Clients
This is important information for taxpayers who are remunerated for work outside SA. An amendment to the Income Tax Act, tucked away on page 138 of Annexure C, will significantly affect the taxation of foreign remuneration.
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.
The effect is that if you are a South African tax resident, and you earn foreign remuneration, that foreign remuneration will not be exempt unless it is already taxed in the country where the services are rendered. Effectively, the free ride is over. The amendment ensures that you will pay tax either in SA or abroad.
I'm very happy to field your questions in this regard. Due to the anticipated volume of emails, please allow me a few days to respond to you individually.
Please also take a moment to reflect on the proposed Government expenditure, as highlighted in my email last night. This will put you in a position to appreciate what Government propose to do with the tax they are going to withhold from you.
Regards
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