Global ETD Search
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Showing 1 to 19 of 19 for “"Income tax law"”.
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Transfer Pricing in South African income tax law
… will remain, the most important international tax issue facing MNEs.' The term 'transfer pricing' is used to describe arrangements involving the transfer of goods or services, at an artificial price, in order to transfer income or expenses from one enterprise to an associated enterprise in a …
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A comparative analysis of the concept of fiscal jurisdiction in income tax law
… rules of fiscal jurisdiction as well as the tax consequences resulting from the application of these rules, as implemented in the national tax law of the chosen jurisdictions. In essence, there are two main rules, which give content to the chosen theory of fiscal jurisdiction, mainly source …
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The deductibility of interest expenditure in leveraged buyout transactions under South African Income Tax Law : a critical examination of recent developments
… to provide an overview of the South African tax law principles governing the deductibility of interest expenditure incurred by taxpayers in respect of LBO transactions, as altered by the recent changes to the Act, and secondly, to critically consider and comment on the nature and perceived …
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The source of income in South African income tax law and the inward and outward structuring of investments into and out of South Africa
… inward and outward investment. The South African income tax system is · based on the source of income. There is a limited reliance on the residence principle. It is essential to understand the scope of the source principle in both inward and outward investment. This thesis attempts to discuss …
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The relevance of the OECD BEPS action plan 2 recommnedations for selected aspects of cross border arbitrage through selected hybrid instruments and entity arrangements in South African Income Tax Law
… comprising recommendations on domestic law and double tax convention measures. This dissertation assesses the potential implication of these recommendations for South Africa's tax laws and double tax conventions as these relate to cross border financing arrangements between two taxpayers …
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Controversias constitucionales en la interpretación de la base imponible del impuesto por distribución de utilidades de sucursales en el país de entidades no domiciliadas
… by the interpretations of SUNAT and the Tax Court of the Second Paragraph of Subparagraph e) of the Article 56 of the Income Tax Law that regulates the tax basis of the tax for the dividend’s distribution from branches in Peru to no-domiciled head office. Both SUNAT and the Tax Court …
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Deductibility of actual expenditure and losses incurred, respectively, as a result of theft or defalcation and liability for damages or compensation
The area of income tax law in South Africa pertaining to the deductibility of expenses and losses incurred, respectively, as a result of theft or defalcation, on the one hand, and liability for damages or compensation, on the other, is replete with uncertainty particularly in light of the courts' …
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Problemática del impuesto a la renta que enfrentan los clubes de fútbol en el Perú
Through Law 29504, which promotes the transformation and participation of Professional Football Sports Clubs into Public Limited Companies, Article 5 introduces for the first time the open public limited company as the legal form of sports clubs. This article develops the Income Tax (IR) from the …
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The taxation of trust income in South Africa
… of trusts, even in the particular area of income tax, is vast. Therefore, it is important that I discuss from the outset the outline of my approach in order to give my treatment of the subject under consideration form and direction. And that is what I propose to do briefly here. The …
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The perennial problem: a critical analysis of the income versus capital distinction in respect of share transactions in the new "Digital" economy
… the application of the test used to distinguish income from capital in South African Income Tax law and critically analyse the problems associated therewith. Such problems relate to the nature of a receipt or accrual upon the disposal of an asset as well as a range of other receipts and accruals …
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Changing taxpayer attitudes and increasing taxpayer compliance: the role of individual differences in taxpayers
The level of taxpayer compliance has steadily decreased over the years. Individual taxpayers failed to report approximately $100 billion in federal taxes due on legal income received in 1989. The compliance gap is large enough to greatly reduce the federal government deficit. Studies employing …
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A group income tax system for South Africa
This thesis establishes a group income tax system for South Africa so that equity may be achieved between the burden of company income tax borne by shareholders who invest in companies that are structured through subsidiaries and shareholders that invest in companies that are structured through …
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Potential impacts of various capital gains tax structures on forest investments
… study was to determine how various capital gains tax structures affect decisions to invest in new forest investments. These effects were measured by changes in the after-tax present values of bare land under each tax structure. The three capital gains tax structures modeled were: the current …
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An investigation of the relationship between the presence of U.S. employees abroad and the changes in the taxation of their foreign earned income
Since 1926, Congress has granted substantial tax benefits to encourage U.S. citizens to accept employment positions abroad so that they might, in turn, support the export of U.S. goods and services. The purpose of this study was to determine whether changes in the taxation of foreign earned income …
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Income taxation by residence and/or source in Lesotho
"The Income Tax Acts themselves impose a territorial limit; either that from which the taxable income is derived must be situate in the United Kingdom or the person whose income is to be taxed must be resident there", per Lord Herschell in Colquhoun v Brooks (1889) 2 TC 490 at 498 These remarks by …
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History and development of the net operating loss deduction in Federal income taxation
Electronic Thesis or Dissertation
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Diferencia en cambio y provisiones contables: tratamiento contable y tributario en el Perú
¿Cuál es el alcance del tratamiento tributario aplicable en el Perú a la diferencia en cambio?, ¿qué debe entenderse por operaciones, y por objeto habitual de la actividad gravada? En relación a las provisiones contables, ¿corresponde reconocer una ganancia o pérdida por diferencia en cambio, como …