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 65 for “"International Tax"”.
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International tax planning for Maltese companies
Globalisation is inevitable, and so is international tax planning. International tax planning is a regular feature of business life that involves the quantification of the tax cost of carrying out foreign transactions, and the arrangement of the tax affairs so that no more tax is payable than is …
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International tax planning considerations for South African emigrants
The purpose of this paper is to outline the international income tax implications facing a South African emigrant. The discussion that follows is based on an individual or family emigrating from South Africa to Australia. The reason why I have chosen Australia is because I have a detailed knowledge …
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International tax planning and anti-tax avoidance provisions - Hila Zetler.
'The avoidance of tax may be lawful, but it is not yet a virtue' – Lord Denning¹. The famous English judge, Lord Denning, explained that the avoidance of tax may be legal, but it is not necessarily ethical. By said words, Justice Denning implied that, when a taxpayer avoids paying taxes through …
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International Tax Planning: The Concept of Place of Effective Management
… certain aspects of the South African Income Tax Act2 such as residence-based concepts, with specific reference to place of effective management, which brings a taxpayer within the ambit of the South African Tax Law. It will also address issues regarding Double taxation agreements and the …
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Planning for a "sudden-death" inventory loss triggered by international tax competition
This study addresses a medical device company's need to relicense its products for export after declaring a new legal manufacturer. New license applications are approved at an unknown date with increasing probability within a finite time horizon. Approval results in the instantaneous obsolescence, …
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Challengers posed by electronic commerce to certain traditional concept in international tax law
… fiscal regimes, both from a domestic and an international perspective. It is against this background that I elected to research and present a dissertation on the implications of electronic commerce on certain aspects of international fiscal law. To give a more balanced perspective, I decided …
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Scope for use of tax havens by South African residents in international tax planning
… of paper: to consider the scope for use of tax havens by South African residents (individuals and companies) in international tax planning, and specifically, within this, whether this scope is reducing given recent changes both in the international regulatory environment and in the South …
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Inter-nation tax equity: An enquiry into the distributive justice concerns of international tax allocations between countries
… thesis examines whether the economic benefits of international commerce are or can be equitably distributed between countries through international tax systems. It explores how international tax revenue is presently allocated between nations and considers how such allocations could be made more …
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Legal aspects of international tax planning for sportspeople and entertainers: a critical examination from a UK perspective, with comparative analysis from a US perspective, of the degree to which offshore financial centres can provide effective tools for international tax planning for sportspeople and entertainers
… thesis stated that academic research into international tax law was in its early stages of development. Today, with the increasing globalisation of finance, the growth in offshore financial centres and the unprecedented mobility of capital and labour, the need for such continued research is …
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Tackling international tax avoidance: If South Africa has general anti-avoidance rules, why does it need the principal purpose test?
… OECD's Final Report on BEPS Action 6, the Davis Tax Committee observed that the GAAR and the PPT serve a similar purpose and that the GAAR can be applied to prevent the abuse of treaties. They stated further, that one could therefore argue that there is no need for South Africa to amend its …
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The international tax consequences arising on the death of South African individuals owning Greek or Portuguese property and Greeks or Portuguese owning South African property
South Africa levies two taxes on an individual in the event of death; namely estate duty and capital gains tax. Much debate exists on whether it is fair for South Africans to pay a "double tax" on the same assets on death. There is also a possibility that the deceased becomes liable for a third tax …
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The effect of the Coca-Cola transfer pricing cases and selected shifts in the international tax regime on the determination of an arm's length price
… legal loopholes and opportunities for double non-tax, along with economic, social and political developments in modern history have driven significant changes in the international tax environment facing taxpayers with cross border interests. Transfer pricing and the arm's length calculation is …
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BEPS action 14 – the effectiveness of the dispute resolution proposals, with specific reference to South Africa
… with the G20 and other states to reform the international tax framework. The reform was necessary to deal with the challenges posed by globalisation. The existing international tax framework had not changed for many years and was unable to deal with these new challenges. As stated by the OECD …
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A critical analysis of whether BEPS Action 1 resolves issues of source taxation
… economy and the challenges it poses to the international tax arena is a swiftly developing area. This dissertation considers the suggestions released by the OECD Pillar 1 dated January 2020 and the UN Article 12B released in August 2020. The digital economy has evolved significantly over the …
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Transfer pricing: a comparison of the German and the South African system
… The growth of MNEs presents increasingly complex taxation issues for both tax administrations and the MNEs themselves since separate country rules for the taxation of MNEs cannot be viewed in isolation but must be addressed in a broad international context." These are the first few words of the …
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Developing a foundation for a globally coordinated approach to the taxation of crypto-asset transactions
… created much uncertainty within the field of taxation. While some jurisdictions have attempted to formulate responses, others have yet to meaningfully engage with the topic. In contrast to the taxation of the digitalised economy, a coordinated global approach to the taxation of crypto-asset …
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Does the proposed dividends tax overcome the international tax flaws that secondary tax on companies may have, namely exclusion from the scope of some double tax agreements and violation of the anti-discrimination provisions embodied in the OECD mode
Secondary tax on companies (STC) and the new dividends tax and its exemptions therefrom could be in contravention of the non-discrimination provisions of Article 24(5) of the OECD MTC. This question has not been decided in a South African court. This dissertation proposes the resolution to this …
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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 taxation of non-resident entertainers and sportspersons
… a right to reap some form of payment, through taxation, for the use of their resources. Given the large quantum circulating amongst these performers, it is a fairly lucrative source of economic revenue for the respective countries' tax authorities. In South Africa it is of considerable …
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