The Saving Grace for Cross-Border Earners:
Double Taxation Agreements Explained
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1. Introduction
2. Key challenges expatriate rotational workers and remote earners face
3. Foreign Income exemption (Section 10(1)(o)(ii))
4. What is a Double Taxation Agreement (DTA)?
5. The Tie-Breaker Test: How Exclusive Tax Residency is determined
6. Financial Emigration
7. Why South African Expats Should Care About Tax Residency
8. Why DTAs are a Saving Grace for rotational workers and remote earners
Many taxpayers only discover the value of a DTA when it is too late – after assessments, penalties, or unexpected liabilities arise. Register now to understand the relief mechanisms available to you and how to apply them correctly before you are left with an expensive surprise!
John-Paul Fraser
Manager: Cross-Border & Expatriate Taxation
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John-Paul Fraser is an Admitted Attorney of the High Court of South Africa and the Team Lead for Expatriate & Cross-Border Taxation at Tax Consulting Africa. John-Paul has completed his BCom Law and LLB degrees, respectively, finishing as a Top Law Graduate in the country, he is recognised for his expertise in global mobility, international taxation, and cross-border retirement planning.
John-Paul advises on the complex interaction between domestic tax law and international legal frameworks, ensuring expatriates and globally mobile individuals receive accurate and compliant tax treatment across jurisdictions.
He has made multiple appearances in Parliament and before National Treasury, advocating for the protection of South African expatriates’ rights and access to tax relief.
John-Paul also serves as the Expatriate and Cross-Border Tax specialist on the SAIT Helpline, where he assists tax practitioners nationwide with advanced technical queries involving tax residency, international tax treaties, offshore remuneration, and international mobility compliance.
Brigitte Bufé
Tax Practitioner
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Brigitte Bufé is a registered Tax Practitioner, with over four years in the tax returns department, providing comprehensive advisory and compliance services. She specialises in local and expatriate taxation, offering tailored solutions to individuals and internationally mobile employees navigating complex cross-border tax obligations.
Her expertise includes preparing and reviewing complex income tax returns and delivering strategic expatriate tax solutions, such as managing foreign income reporting and advising on the tax implications of international assignments. Brigitte ensures efficient tax structuring, accurate residency classification, and full compliance with local laws. She supports clients through every stage of the tax process, from initial planning and precise filing to effective communication with tax authorities, while identifying opportunities for tax optimisation.