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 12 of 12 for “"Double Non-Taxation"”.
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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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An analysis of options for reform of South Africa’s unilateral income tax exemption of foreign pensions, with an emphasis on the cross-border interaction with pensions derived from the United Kingdom and Germany
… recently reformed the tax policy regarding the taxation a South African resident’s foreign employment income and is in the process of reviewing the tax policy of foreign pensions. The unilateral foreign pension exemption was only meant to be on a temporary basis, but yet uncertainty existed ever …
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Will the steps taken by South African expatriates to circumvent section 10(1)(o)(ii) trigger the South African GAAR?ar?
… for the amendment to the Act is to prevent double non-taxation. Double non- taxation arises when a South African expatriate is working in a tax-free jurisdiction, for example the United Arab Emirates (UAE; the country used as reference for the purposes of this study), where no tax is levied …
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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 History and Relevance of the Beneficial Ownership Concept in Tax Treaties ? Specifically in the context of the Introduction of the Principal Purpose Test
… texts. Information from academic literature, double tax agreements, domestic legislation, OECD MTC (reports, commentaries, and materials) and international case laws were collected. Thereafter, a qualitative analysis was conducted to gain a clearer and more comprehensive understanding of the …
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A critical analysis of the recent change to the unilateral foreign employment income tax exemption in South Africa and its cross-border interaction
… (BEPS) recommendations and the tackling of double non-taxation. In 2017, the National Treasury announced that the tax exemption for South African expatriates would be changing. The section would be amended so that foreign employment income would no longer be fully exempt in the hands of a …
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An analysis of the Murabahah Islamic Finance Instrument in the context of article 11 of the OECD model tax convention on income and capital
… and complex in this regard. So much so that non-traditional sources of financing have become more prominent as a viable alternative where we have seen a considerable increase in their use. This is evident with the steady growth and expansion of Islamic finance within the wider umbrella of the …
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A technical analysis of the difference in treatment of technical fees in relation to the receipt of management fees by a resident of South Africa, sourced from Botswana and Zambia, including the impact of domestic and treaty relief
… establishment or fixed base. This phenomenon proved problematic, especially in developing countries who are large importers of services, in that the country paying for the services would not be in a position to tax these activities however would, in terms of application of their domestic …
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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 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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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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The suitability and practicality of the OECD transfer pricing methods to Zimbabwe
… economic situation is considered. As a taxation tool, the guidelines' suggested methods have been applied with a lot of challenges, sometimes resulting to unwarranted loss of revenue with comparability being the major source of difficulties. It is against this backdrop that it was found …