Global ETD Search
Search theses and dissertations gathered from participating repositories worldwide. Every result links back to the library that holds it. No account is needed.
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Showing 1 to 20 of 70 for “""Double Taxation""”.
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An analysis of the methods used in the South African domestic legislation and in double taxation treaties entered into by South Africa for the elimination of international double taxation
… the context of methods relieving international double taxation and in the context of a recently opened and developing economy.
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Exit taxes in the context of double tax treaties: is the individual emigrating from South Africa protected against double taxation?
… is a taxable event and may give rise to taxation of capital gains, based on a deemed disposal, even though there has not been an actual realisation of the capital gain. Such taxation is referred to as ‘exit or departure tax’ or ‘exit charge’. Double taxation of capital gains may arise …
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The legal status of memoranda of understanding in relation to treaties for the avoidance of double taxation and information exchange
… in relation to treaties for the avoidance of double taxation and information exchange has, to a greater extent, not been asked or answered in academic literature. This minor dissertation seeks to address that. Based on a review of the legal framework for treaties and MOUs, analyses of cases …
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Shortcomings of and recommendations to improve double taxation relief mechanisms: a study of South African resident companies engaged in the exploration for and production of oil and gas outside of South Africa
… and gas outside of South Africa are subject to double taxation. This thesis evaluates whether South African resident companies engaged in the exploration for and production of oil and gas outside of South Africa receive full relief from double taxation in South Africa. The thesis provides a …
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The fiscal residence of natural persons as it applies to South Africans working abroad: A study of South Africa, United States of America, United Kingdom and Australia and agreements for the avoidance of double taxation
… Trevor Manuel introduced the residence basis of taxation in his 2000 budget speech, thus ensuring that South African residents (as, defined in the Income Tax Act 58 of 1962 (as amended)(the 'Act')) became taxable on their worldwide income. This paper explores the South African ('SA') residence …
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Some aspects of estate duty on deceased estates in the Republic of South Africa: with special reference to the problems and effects of double taxation occuring in relation to the German Erbschaftsteuergesetz (Inheritance Tax Act)
… death, always that certain? The avoidance of double taxation has been an objective of most of the world's nations since the negotiation of the first Income Tax Convention in the middle of the nineteenth century. The development of most of the world's countries into modern industrial nations, …
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Potential Cross-Border Double Taxation on Death Limits Global Investment Opportunities for Long Term South African Resident Investors - demonstrated through an analysis of the international tax consequences that arise for a South African resident who holds an investment in a portfolio of stock listed in the United States of America at the date of death
… SA at the date of death may result in unresolved double taxation or at the very least the imposition of taxes that are confiscatory, excessive or prejudicial to SA resident investors. In order to demonstrate that double taxation may exist or that confiscatory, excessive and prejudicial taxes may …
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Resolving double non-taxation : issues regarding the foreign employment income exemption in South Africa
… tax based on their worldwide income. Worldwide taxation may result in double taxation if the resident of a state earns income from another contracting state which believes it has the taxing rights to the same income. Relocation to other countries for work purposes has become very popular amongst …
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The double tax consequence of the new double tax treaty between South Africa and Mauritius for persons other than individuals
… business activities. In 1996 SA concluded a double tax treaty ('DTT') with Mauritius to guard against potential double taxation. This could occur when a person is considered a tax resident in both South Africa and Mauritius by virtue of the application of the respective tax laws of these …
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Essays on insurance and taxation
Chapter 1 analyzes Pareto optimal non-linear taxation of profits and labor income in a private information economy with endogenous firm formation. Individuals differ in both their skill and their cost of setting up a firm, and choose between becoming workers and entrepreneurs. I show that a tax …
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The taxation of non-resident entertainers and sportspersons
… a right to reap some form of payment, through taxation, for the use of their resources. Given the large quantum circulating amongst these performers, it is a fairly lucrative source of economic revenue for the respective countries' tax authorities. In South Africa it is of considerable …
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Domestic deeming provisions and double tax treaties: lessons from Tradehold and Fowler
… provisions in South African domestic tax law and double tax treaties (‘DTTs'), focusing on the legal and interpretative challenges that arise when statutory fictions are applied within an international tax framework. Using a comparative analysis of Commissioner for the South African Revenue …
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The taxation of 'Influencers' in South Africa and in an international context
… perspective, it became evident that their taxation is guided by existing legislation rather than specific provisions tailored for them. In South Africa, the classification of Influencers as employees or independent contractors holds crucial implications for their tax treatment. Notably, the …
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The Taxation of International (non-resident) Sportspersons in South Africa
… of the sportsperson article in South African Double Tax Agreements (DTAs), the withholding tax applied to sportspersons performing in South Africa is analysed against the sportsperson article to determine whether these are appropriately aligned. The interpretational rules applicable to fiscal …
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A comparative analysis of the foreign tax credit system of South Africa, with specific reference to corporate taxpayers and technical service fees
… has often resulted in increased instances of double taxation for South African corporate taxpayers, as a result of the fact that the majority of the jurisdictions in Africa apply a withholding tax on technical service income paid to nonresidents. The ability to claim relief for the juridical …
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A study of the legal effect of the main provisions of the income tax treaty between France and the United Kingdom
… to be the first exhaustive work on the 1968 double taxation agreement between France and the United Kingdom. An attempt has been made to provide a comprehensive and thorough analysis of this particular tax convention. The thesis first investigates matters relevant to all categories of …
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An analysis of the effect of the amendments to the taxation of foreign non-South African employment income
… a source based to a residence based system of taxation on 1 March 2001, all South African residents were now being subject to tax on their world-wide income. Residents working outside the Republic were then at risk of being taxed twice on the employment income derived because of South Africa’s …
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The implications of wealth transfer taxation in the absence of estate duty
… which include the following: - The perceived double taxation at death of an individual if capital gains tax is considered, - With estate duty being classified as a "wealth tax", the wealthy are more inclined to avoid these taxes by setting up trusts and paying for elaborate estate planning …
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A critical analysis of whether BEPS Action 1 resolves issues of source taxation
… will explore the theories that justify taxation at source. For a tax-compliant culture to exist, it is vital that taxes raised are just.4 It will be shown that the theories that justify taxation at source are relevant to the digital economy and will ensure just taxation at source. To get …
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Reforming Foreign Tax Credit System in China with a Liberal Approach: A study of Foreign Tax Credit and Related Rules of International Taxation on Residents’ Foreign Source Income
… should be embodied. Relieving international double taxation is the foremost purpose as well as principle, and defeating tax escaping, protecting resident country’s tax base is the other one. Three aspects are viewed as criteria to evaluate international taxation policy traditionally. They are …
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