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 “"Foreign company"”.
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Assessment of the purpose of South Africa's controlled foreign company rules
Controlled foreign company (CFC) rules are anti-avoidance provisions designed to deter taxpayers from shifting their capital (and resultant income) to low-tax jurisdictions. Adoption of these rules in South Africa coincided with the relaxation of exchange control laws which opened up borders to …
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A critical analysis of statutory deeming in the context of the interaction between South Africa's controlled foreign company regime and model-based bilateral tax treaties
… of the ‘as if' fiction in British Controlled Foreign Company (CFC) rules. In that case, the court found that the reference to ‘as if' was a purely notional definition based on fictional assumptions. These assumptions resulted in a product of artificial calculation, such that when constructed …
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An analysis of the possible fiscal consequences of a controlled foreign company being declared resident in South Africa– may SARS have its cake and eat it?
… is raised are as follows: suppose that Company A, a South African resident, owns 100% of the participation rights in Company B (the hypothetical taxpayer), a resident of Luxembourg. Company A has failed to qualify for any of the internal “exemptions”1 contained in section 9D of the …
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Greening the economy : a case study to identify a different approach to encourage sustainability
… behaviour of businesses. A local listed company was selected and researched to identify ways in which the business uses by-products in a resourceful way that is both good profitability as well as the environment. The study was extended to a similar foreign company and further innovative …
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Social Psychology of Globalization: Joint Activation of Cultures and Reactions to Foreign Cultural Influence
… and space—people are often exposed to local and foreign cultural symbols simultaneously. Psychological consequences of this kind of cultural exposure (termed bicultural priming) remained largely unexplored. This research examines how bicultural priming influences individuals’ reactions to foreign …
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Startups in South Africa, Barriers to Growth and Opportunity through Unconventional International Structures
… structure, which entails an offshore holding company with South African shareholders, which owns a South African entity – as well as the current legislation and restrictions in place which regulate the loop structure, also taking into account market opinion and the recent legislative …
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Employer-assisted housing in maquiladoras in Mexico : a case study of the Delphi Automotive Housing Program
… cities. Grupo Condak, a Mexican construction company, would build the homes with the financial backing of Pulte Mortgage Company, the largest US homebuilder at the time. The Mexican government has attracted foreign direct investment through the maquiladora program because of low labor costs …
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The suitability of the South African corporate tax regime for the use of South African resident intermediary holding companies
An Intermediary Holding Company (“IHC”) is a company that is interposed between an ultimate holding company and the operating subsidiaries of a group of companies. The IHC operates at an international level such that either its holding company or its subsidiaries or both are located in a country …
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English proficiency of Vietnamese business graduates: Requirements of government, private universities, and foreign employers
… It is also the official language in many foreign companies (Kam, 2002) and proficiency in English is therefore an advantage for acquiring employment in foreign companies where the working environment is multilingual, professional and highly competitive. As a dynamic developing country in …