Benjamin is 51 years old, lives in America, and is a non-resident for South African income tax purposes. Benjamin has never been to South Africa. Benjamin granted a loan to his cousin’s construction company, Build-it Limited. Build-it Limited does construction work in South Africa, and the company’s place of effective management is in America. Interest to the value of R130 000 on this loan accrued to Benjamin for the 2022 year of assessment.