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 56 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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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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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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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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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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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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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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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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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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The creation of a permanent establishment in South Africa as a result of the activities or presence of a partner or partners in South Africa
… to determine the potential application of double taxation agreements to partnerships or their partners. Once the terms of a double taxation agreement are found to apply in the circumstances, the creation of a permanent establishment in terms thereof becomes relevant. The different types of …
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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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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
… authorities in that it resulted in unrelieved double taxation or double non-taxation which in turn causes difficult disputes whilst consuming scarce resources. In light of this, a new Article 12A- Fees on technical services had been drafted into the 2017 United Nation Double Taxation Convention …
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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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International Tax Planning: The Concept of Place of Effective Management
… Tax Law. It will also address issues regarding Double taxation agreements and the impact of all these issues on companies trading internationally. This paper is intended to raise an awareness of the current issues, general principles and practices to be taken into account when organizing a …
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Two Essays in Business Cycle Theory
… essay evaluates the effectiveness of the "end of double tax" policy in stimulating an economic recovery by analyzing the transitional dynamics of the economy's aggregates toward the steady states. The effectiveness of this policy is compared with two alternative policies that reduce corporate …
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A critical evaluation of the 1964 preferencial agreement (Labour agreement) for Mozambique mineworkers in the light of the South Africa - Mozambique DTC and the SADC treaty
… Many countries in the SADC region enter into double taxation agreements for the avoidance of double taxation. The 1964 labour agreement is quite unique as the income received by the Mozambican mineworkers is exempt from tax in South Africa for the duration of the contract (usually up to 18 …
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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
… the existing tie-breaker rule in South Africa's Double Taxation Agreements (“DTAs”) to solving cases of dual residency through a Mutual Agreement Procedure (“MAP”). The MLI's approach of using MAP as a tie-breaker includes a non-exhaustive list of criteria that tax authorities may consider as …
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Trading stock : a critical analysis of the application of Section 1 of the Income Tax Act no 58 of 1962
… based on connection to jurisdiction. Taxation is divided into international and domestic systems. An international tax system subjects its residents to tax on their income from all around the world while a domestic tax system subjects its residents to tax only on income arising out of …
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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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