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 11 of 11 for “"Base Erosion and Profit Shifting (BEPS)"”.
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A study of the democratic legitimacy of Action 13 of the OECD's base erosion and profit shifting (BEPS) Action 13.
… 13 of the Organisation for Economic Cooperation and Development's (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan. Taking a critically orientated philosophical position, the thesis draws data from a stakeholder consultation conducted by the OECD which is coded to allow statistical …
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Siezing the BEPS: an assessment of the efficacy of South Africa’s thin capitalisation regime in combating base erosion and profit shifting (BEPS) through excessive interest deductions
… thin capitalisation framework in dealing with Base Erosion and Profit Shifting (BEPS) through excessive interest deductions by multinational enterprises (MNEs). Given the impact of globalisation in interconnecting economic activities across multiple countries, BEPS presents a major policy …
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The possibility of base erosion and profit shifting through special economic zones: A critique of the South African and Kenyan SEZ regimes based on BEPS action 5
The OECD/G20's Base Erosion and Profit Shifting (BEPS) Project has been described as the most significant international tax initiative post the 2008/2009 global economic crisis. BEPS speaks to companies engaging in aggressive tax planning strategies that exploit loopholes in tax systems to make …
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An analysis of the current framework for the exchange of taxpayer information, with special reference to the taxpayer in South Africa's constitutional rights to privacy and just administrative action
… years, especially in the light of the G20 led Base Erosion and Profit Shifting ('BEPS') Project. Ensuring that the fundamental rights of the taxpayer, guaranteed by the Constitution1, remain protected amidst the hurried implementation of these reforms is of paramount importance and cannot be …
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Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector
… on the Organisation for Economic Co-operation and Development ('OECD') transfer pricing methods and its application to Multinational Enterprise ('MNE') groups in the financial sector. This study examines whether the OECD's Base Erosion and Profit Shifting ('BEPS') Action Plan 9 is an …
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An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective
… published a report on its findings concerning base erosion and profit shifting ("BEPS").1 That report, in particular Action Plan 13, dealt with the re-examination of transfer pricing documentation wherein the shifting of profits to lower tax rate jurisdictions is addressed. The OECD proposed a …
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The taxation of trusts in South Africa: Critical analysis of Section 7C
… 7 as well as international trends including the Base Erosion and Profit Shifting (BEPS) final reports. As globalisation accelerates and data becomes more readily available to both developed and developing economies the transparency of structures will become more evident and the previously …
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The source of income from the sale of goods electronically: an analysis of the division of the taxing rights in cross-border solutions
The digital economy is rapidly evolving and changing the way businesses operate. This is as a result of the increased use and reliance of technologies in business processes. As more companies adopt technology in their operations and as technology is continually developing, it becomes cheaper to …
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A critical analysis of the impact of the MLI in the determination of corporate residency in South Africa: a synthesis of a hierarchy of factors to used for resolving dual residency under map
… Africa has deposited its ratified, accepted, and approved MLI and list of reservations and notification with the OECD on 30 September 2022. The MLI applies from 1 January 2023 in South Africa. In alignment with the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (“BEPS”) …
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A qualitative analysis of the international conformity of the proposed amendments to section 23M of the Income Tax Act No. 58 of 1962
Base erosion and profit shifting (BEPS) is the practice whereby multinational entities use tax planning mechanisms to exploit gaps in tax legislation to avoid a potential tax liability. In order to address this risk in South Africa, the Government previously introduced, amongst other things, …
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An analysis of the digital services tax solutions presented in Africa and early-adopting developed countries to inform South Africa on the design features for taxing the digital economy
… adopt the Organisation for Economic Co-operation and Development's (“OECD”) Two-Pillar Approach and is currently preparing for Pillar Two's implementation, as the design and consensus for the implementation of Pillar One is progressing at a slower pace. While both pillars originated from the need …