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 18 of 18 for “"Cross-border transactions"”.
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Establishing the residency of artificial persons in cross border transactions
The basis of residence taxation is that residents enjoy protection in the state where they contribute towards the costs of government. In tax treaties residence is used for purposes of allocating income and taxing rights between contracting states. For treaty purposes residence is determined on a …
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Managing cross-border transactions-legal framework, strategies and incentives from the participants.
Managing a company requires taking actions and decisions every day. As being a legal entity, an abstract conglomerate of assets, contracts, rights and obligations, a company can only act and express intention through its managers. Whereas the company’s defined object is the purpose and direction …
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Value added tax - place of supply and the taxation of the electronic cross border supplies of services and intangibles
… concern of this dissertation is the reduction of cross-border tax obstacles by improving the VAT rules governing cross border supplies of services and intangibles. These cross-border transactions are on the increase for many countries around the world. Cross-border transactions come with many …
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Transfer pricing
… associates through under or over pricing of cross border transactions. Tax avoidance, was at the centre. Tax avoidance, today if present, is at the margins, not at the centre. Transfer pricing is a neutral concept. Often, it is used incorrectly in a pejorative sense, to mean a pricing …
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The UNIDROIT Principles of lnternational Commercial Contracts and South African Contract Law
… legal solutions that are not appropriate to cross-border transactions at all.
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Trading stock : a critical analysis of the application of Section 1 of the Income Tax Act no 58 of 1962
… on income arising out of a source within the borders of such a State. Under the international tax system, a State's right to tax firstly depends on whether the taxpayer deriving the said taxable income is a resident of that country or not. With respect to an entity or enterprise, its place of …
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Do the South African headquarters provisions provide a competitive alternative for a gateway into Africa for international companies?
… companies in particular those involved in cross border transactions into its jurisdiction by introducing its Headquarter Company Regime.
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A critical analysis of SARS' implementation of Advance Pricing Agreements
… a topical issue globally. The increase in cross-border transactions by multinational enterprises due to globalisation and internationalisation has increased the complexity of these transactions. This has resulted in lengthy and costly dispute resolution processes that pose uncertainty for …
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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
… effect of the imposition of these two taxes on cross-border transactions; this study examines the international tax consequences that arise on death, should a SA resident investor hold foreign situs assets at such time. The study uses a portfolio of stock listed in the United States of America …
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A critical analysis of the regulation of crowdlending : a local perspective
… hence there is the predominant possibility of cross-border transactions taking place and jurisdictional issues may arise. The different cross-border scenarios that may arise are analysed to see how current regulation would apply to such scenarios. The thesis then sets out a number of regulatory …
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Adoption of a Digital Currency Towards a Singular Continental Market: A Catalyst for African Economic Integration and Revolutionising Pan-African Trade Payment Systems
… to foster regional integration and facilitate cross-boundary trade. African states, recognising this potential, are exploring the creation of Central Bank Digital Currencies (CBDCs) to harness the advantages of decentralised technology while maintaining regulatory oversight. The inherent nature …
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The OECD transfer pricing guidelines: an analysis of their application in the South Africa legal regime
… the Income Tax Act 58 of 1962 governing certain cross border transactions amongst entities form the basis of transfer pricing legal regulatory regime in South Africa. The arm's length principle forms the backbone of applying the provisions of the section. The existing legislation is wide in scope …
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Sustainable business strategies with policy-driven economies
… and institutional investors engaged in cross-border investments. These regulations include temporary halts of various programs such as the Qualified Domestic Institutional Investor Scheme and the Qualified Domestic Limited Partner initially devised to facilitate a smooth capital flow in …
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In search of coherence and consistency in European contract law: a way forward
… functioning of the internal market and for crossborder trade from the existing divergent and fragmentary state of European contract law at the EU and national levels. This question was answered in the affirmative. Action was needed to simplify the regulatory environment for cross-border …
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Transfer Pricing in South African income tax law
… of income and expenses of related-party transactions. Another key issue, closely related to transfer pricing, is that of double taxation. Multinational enterprises, engaging in cross-border transactions, are at risk of having a single source of income taxed in two jurisdictions as a …
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Enforcing foreign arbitral awards in Indonesia: Overcoming disharmony between international and domestic laws
… business people settle disputes arising out of cross-border transactions. Having ratified relevant United Nations (UN) conventions as a dualist country, Indonesia has transformed various provisions into its domestic law. However, there is a gap between Indonesia’s international obligations and …
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A critical analysis of South Africa’s domestic nexus requirements for the taxation of cross-border services
The taxation of cross-border services has for a long time been a contentious topic of discussion across the international tax arena. The controversy of this debate stems predominantly as a result of the long held notion of the permanent establishment as a nexus requirement for source taxation; in a …
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Cross border tax assistance as a framework for revenue mechanism
… or on time or in their full amount within the borders of South Africa. The issue arises when a taxpayer leaves their jurisdiction without settling the tax debt or has no asset within the jurisdiction that may serve to recover the tax debt. Tax authorities across the globe have thus come up with …