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(1) What is the source of income generated from electronic commerce conducted between a non-resident e-business and South African residents under South African law? (1) Are the concepts place of effective taxation of income generated by non-resident e-commerce businesses under South African law? (3) An eveluation of the possible interpretation of the concepts of change of intention and carrying on a business when determining whether the proceeds of the sale of an asset by taxpayer is capital or revenue in nature

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