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Showing 1 to 1 of 1 for “"Dual residency"”.
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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
… 4(1) deals with the determination of corporate residency and modifies 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 …