Yes. There are provisions relating to foreign business establishments which result in net income being excluded for substantive businesses such as: a) a suitably equipped and staffed fixed base of business located outside South Africa solely or mainly for a purpose other than tax. b) a construction site lasting for at least 6 months. c) agricultural land used for bone fide farming activities. d) ships, vehicles, rolling stock and aircraft operated by the CFC or group company in a particular country.