SAICA Comments on the Draft Interpretation Note on vesting of income in a resident beneficiary by a non-resident trust

SAICA submission on on the Draft Interpretation Note providing clarity on the interpretation and application of the words "subject to the provisions of section 7" in section 25B(1) and, more specifically, whether section 7(8) or section 25B(1) applies when income received by or accrued to a non-resident trust by reason of or in consequence of a donation, settlement or other disposition by a resident, is vested in a resident beneficiary by the trustees of the non-resident trust.