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 9 of 9 for “"Double tax treaties"”.
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Domestic deeming provisions and double tax treaties: lessons from Tradehold and Fowler
… deeming 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 …
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Does a mineral right constitute 'immovable property' for purposes of the Income Tax Act and double tax treaties?
This research paper analyses the income tax impact for international (non-resident) companies that dispose of their shares in mining or oil and gas companies situated in South Africa. Typically, a disposal of shares by a non-resident in a property-rich company in South Africa would attract CGT. In …
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Exit taxes in the context of double tax treaties: is the individual emigrating from South Africa protected against double taxation?
… change of residence to another jurisdiction 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 …
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A critical analysis of the taxation of cross-border service fees in South Africa: Motivation for the reinstatement of the withholding tax on service fees
… that South Africa implements laws that seek to tax service fees in an efficient, effective and equitable manner. South Africa’s Minister of Finance and the Davis Tax Committee are amongst the key government stakeholders who have expressed concern regarding the threat that South Africa faces to …
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The Admissibility of Extrinsic Evidence in the Interpretation of Double Tax Conventions - A South African Perspective
… nation clause in the South Africa/ Netherlands double tax convention has once again raised questions regarding the correct approach to the interpretation of treaties in South Africa and what information should be admissible as part of this process. In particular the court's strict approach to …
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Searching for common deviations from South Africaﾒs Tax Treaty Policy: The relationship with North Africa, West Asia and Eastern Europe
… a degree of standardisation of the contents of treaties by their members, Model tax conventions were published by international organisations. Consequently, in 1963, the Organisation for Economic Co-operation and Development (“OECD”) Model was prepared by developed countries of the world and it …
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The taxation of 'Influencers' in South Africa and in an international context
… digital economy. However, existing international tax rules lack specific provisions addressing Influencers, raising questions about their tax treatment and the potential for treaty abuse. This underscores the necessity of exploring how the Influencers are to be taxed within the current legal …
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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
… the Multilateral Convention to Implement Tax Treaty Related Measures of the OECD to prevent base erosion and profit shifting (MLI), the Base Erosion and Profit Shifting Project (BEPS) recommendations and the tackling of double non-taxation. In 2017, the National Treasury announced that the …