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IN 31 (3) VaLue-added tax act: InterPretatIOn nOtes IN 31 (3)
(l) the supply of goods, other than the supply of goods by an inbound duty and tax free shop, which have been imported and entered for storage in a licensed Customs and Excise storage warehouse but have not been entered for home consumption; or
(m) the supply of goods by an inbound duty and tax free shop.
Provided that paragraphs (a), (b), (c), (d) and (i) of this subsection shall not apply in respect of any supply of goods by a vendor if in respect of such goods input tax contemplated in paragraph (b) of the de nition of ‘input tax’ in section 1 has been deducted in terms of section 16 (3) by that vendor or any other person where that vendor and that other person are connected persons.
Section 11 (2) – Zero-rating of supplies of services
Where, but for this section, a supply of services would be charged with tax at the rate referred to in section 7 (1), such supply of services shall, subject to compliance with subsection (3) of this section, be charged with tax at the rate of zero per cent where—
(a) the services (not being ancillary transport services) comprise the transport of passengers or goods—
(i) from a place outside the Republic to another place outside the Republic; or (ii) from a place in the Republic to a place in an export country; or
(iii) from a place in an export country to a place in the Republic; or
(b) the services comprise the transport of passengers from a place in the Republic to another place in the Republic to the extent that that transport is by aircraft and constitutes ‘international carriage’ as de ned in Article 1 of the Convention set out in the Schedule to the Carriage by Air Act, 1946 (Act 17 of 1946); or
(c) the services (including any ancillary transport services) comprise the transport of goods from a place in the Republic to another place in the Republic to the extent that those services are supplied by the same supplier as part of the supply of services to which paragraph (a) applies; or
(d) the services comprise the insuring or the arranging of the insurance or the arranging of the transport of passengers or goods to which any provision of paragraph (a), (b) or (c) applies; or
(e) the services comprise the transport of goods or any ancillary transport services supplied directly in connection with the exportation from or the importation into the Republic of goods or the movement of goods through the Republic from one export country to another export country, where such services are supplied directly to a person who is not a resident of the Republic and is not a vendor, otherwise than through an agent or other person; or
(f) the services are supplied directly in connection with land, or any improvement thereto, situated in any export country; or
(g) the services are supplied directly in respect of—
(i) movable property situated in any export country at the time the services are rendered; or
(ii) goods temporarily admitted into the Republic from an export country which are exempt from tax on importation under Items 470 and 480 of paragraph 8 of Schedule 1; or
(iii) goods in respect of which the provisions of paragraph (b) or (c) of the de nition of ‘exported’ in section 1 apply; or
(iv) the repair, maintenance, cleaning or reconditioning of a foreign-going ship or foreign-going aircraft; or
(h) the services comprise—
(i) the handling, pilotage, salvage or towage of any foreign-going ship or foreign-going aircraft while situated in the Republic; or
(ii) services provided in connection with the operation or management of any foreign-going ship or foreign- going aircraft; or
(iii) the storage, repair, maintenance, cleaning, management or arranging the provision of a container referred to in paragraph (1) (i) of Schedule 1 or the arranging of those services,
where the services are supplied directly to a person who is not a resident of the Republic and is not a vendor, otherwise than through an agent or other person; or
(i) the services of arranging—
(i) the supply of goods as contemplated in paragraph (b) or (c) of the de nition of ‘exported’; or
(ii) the supply of services referred to in paragraph (g) (iv) or (h); or
(iii) the transport of goods (including ancillary transport services) within the Republic, for a person who is not a resident of the Republic and is not a vendor; or
(j) the services comprise the repair, maintenance, cleaning or reconditioning of a railway train operated by a person who is not a resident of the Republic and is not a vendor; or
(k) the services are physically rendered elsewhere than in the Republic or to a customs controlled area enterprise or an IDZ operator in a customs controlled area; or
(l) the services are supplied to a person who is not a resident of the Republic, not being services which are supplied directly—
(i) in connection with land or any improvement thereto situated inside the Republic; or
(ii) in connection with movable property (excluding debt securities, equity securities or participatory securities)
situated inside the Republic at the time the services are rendered, except movable property which—
(aa) is exported to the said person subsequent to the supply of such services; or
(bb) forms part of a supply by the said person to a registered vendor and such services are supplied to the
said person for purposes of such supply to the registered vendor; or
(iii) to the said person or any other person, other than in circumstances contemplated in subparagraph (ii) (bb),
if the said person or such other person is in the Republic at the time the services are rendered, and not being services which are the acceptance by any person of an obligation to refrain from carrying on any enterprise, to the extent that the carrying on of that enterprise would have occurred within the Republic; or
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