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 133 for “"Income Tax Act"”.
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Tax avoidance provisions of the South African Income Tax Act
My thesis is on tax avoidance provisions in South Africa. I want to present an overview of tax avoidance in South Africa but I will concentrate more on section 103(1) which is the general anti - tax avoidance provision in South Africa.I will then proceed to look at the artificial tax avoidance, and …
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Discretionary trusts and section 7 (5) of the Income Tax Act
… popular vehicle in all types of business transactions, due to their extremely flexible nature and the lack of formalities required in their day to day administration. However, largely for the above reasons, there are in my submission a great many questions arising from their existence, the …
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An Evaluation of the Life Insurance Company Income Tax Act of 1959
Made available in DSpace on 2014-12-05T21:04:41Z (GMT). No. of bitstreams: 1 6200556.pdf: 11058684 bytes, checksum: 5f8cf551ab1ffb6e9b9d014f93a3f0bc (MD5) Previous issue date: 1961
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Transfer pricing : an evaluation of section 31 of the Income Tax Act
… legislation as encapsulated in section 31 of the Income Tax Act No. 58 of 1962. Transfer pricing is currently one of the more important short term international tax considerations, specifically in the South African context where recent amendments, particularly with regard to thin capitalisation, …
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Tax planning in the light of tax avoidance provisions in the South African income tax Act Section 103- as amended in the income tax Act No 36 of 1996
… comes to one's mind, in dealing with question of tax planning and tax avoidance is, what is tax planning? What is its significance in the economy of each particular country? How does it affect every taxpayer and what consequences does it have for the Receiver of Revenue? Every country has got its …
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The deductibility of interest expenditure under the Income Tax Act 58 of 1962
… money to acquire assets or finance their trading activities. High gearing of this nature can be highly tax effective, provided the interest on the loan is tax-deductible. However, the deductibility of interest payments has given rise to much litigation. This is indicative of the many complexities …
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Law by Decree: A critique of section 5(2) of the Income Tax Act
… the question of whether section 5(2) of the Income Tax Act 58 of 1962 (the Income Tax Act) infringes upon the Separation of Powers Doctrine and constitutes an unlawful delegation of the power to impose or reduce taxes, in terms of the Constitution. The power to determine the rate of income …
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When is a debt bad or doubtful in terms of the Income Tax Act?
… and doubtful debt allowances provide relief to taxpayers who would be subject to income tax on amounts accrued to them which may never be received. No definition of a bad or doubtful debt is provided in the Income Tax Act. This dissertation considered current legislation, historical court cases, …
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Bitcoin Mining under the South African income Tax Act: a case for a common treatment
… from the 1st October 2001, the basis for taxation in South Africa was fundamentally amended by virtue of the introduction of the Eighth Schedule as the embodiment of a tax regime based on the Haig-Simons comprehensive model of income. It is known as ‘Capital Gains Tax', or CGT, the tax …
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An analysis of the anti-avoidance provisions contained in the South African Income Tax Act
The South African Income Tax Act No 58 of 1962 contains a number of specific as well as general anti-avoidance provisions. This dissertation places its main emphasis of focus on-the general anti-avoidance provisors contained in section 103 of the Act
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An analysis of the anti-avoidance provision S.103 of the South African Income Tax act
The South African Income Tax Act contains a number of specific anti-avoidance sections, as well as a general anti-avoidance section. This dissertation will focus on the general anti-avoidance section 103 of the Income Tax Act No. 58 of 1962 and highlight the individual requirements and their …
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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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An analysis of the anti-avoidance provision section 103 of the South African Income Tax Act 58 of 1962
… their cases may fall outside the scope of the Taxing Acts. They incur no legal penalties and strictly speaking, no moral censure if, having considered the lines drawn by the legislature for the imposition of taxes, they make it their business to walk outside them."1 However, the South African …
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A critical analysis of the reportable arrangements provisions of the Income Tax Act, focusing on section 80M(1)(d)
The objective of this study is therefore to conduct a critical analysis of the language of section 80M(1)(d) in order to determine its nature and scope.
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Strategies to ensure compliance with provisions of the Income Tax Act at the Inland Revenue Regional Office in Walvis Bay
This study focused on the strategies to ensure tax compliance at the Inland Revenue office in Walvis Bay. The main objective of this study was to investigate what are the strategies to ensure compliance with the provisions of the Income Tax Act in Namibia, taking the Regional Office of IRD at …
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Trading stock : a critical analysis of the application of Section 1 of the Income Tax Act no 58 of 1962
The right to tax is traditionally 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 …
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The deduction of repairs to property in terms of section 11(d) of the Income Tax Act 58 of 1962
As the burden borne by the South African taxpayer seems to increase yearly, the prudent taxpayer must embrace the various deductions available to him or her in terms of the Act . In order to do so the taxpayer must understand the ambit of each deduction so that he or she may plan accordingly. A …
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A critical analysis of how paragraph 5 of the tenth schedule interacts with section 20 of the income tax act
… Until 2006, the OP26 lease regime governed the taxation of South Africa's upstream oil and gas mining rights. As the expiration of this regime approached, which coincided with the transition from the Minerals Act to the Mineral and Petroleum Resources Development Act, the National Treasury and …
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A qualitative analysis of the international conformity of the proposed amendments to section 23M of the Income Tax Act No. 58 of 1962
Base erosion and profit shifting (BEPS) is the practice whereby multinational entities use tax planning mechanisms to exploit gaps in tax legislation to avoid a potential tax liability. In order to address this risk in South Africa, the Government previously introduced, amongst other things, …
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