Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions

This dissertation endeavours to analyse the anti-avoidance measures implemented (and planned for the future) in South Africa to combat the practice known as "thin capitalisation". It critically analyses the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions: Thin capitalisation. It concludes that the arms-length approach is not suitable for South Africa and that it is essential that a system of advance pricing agreements be implemented.

Grantor dc:publisher.institution

Department of Finance and Tax

Year dc:date.issued

2014

Author dc:creator

• Beukes, Marvan

Advisor dc:contributor.advisor

• Gutuza, Tracy

Language dc:language.iso

eng

Handle dc:identifier.uri

http://hdl.handle.net/11427/18623

OAI identifier oai:identifier

oai:open.uct.ac.za:11427/18623