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.
Results
Showing 1 to 5 of 5 for “"Multinational entities"”.
-
A qualitative analysis of the international conformity of the proposed amendments to section 23M of the Income Tax Act No. 58 of 1962
… 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, section 23M of the …
-
Will implementing pillar two measures hinder the rehabilitation of South African Mines?
… imposes a global minimum tax of 15 per cent on multinational entities with revenue of EUR750 million or more to prevent large multinationals from shifting their profits to low-taxed jurisdictions. The Global Anti-Base Erosion (“GloBE”) rules and commentary guide the calculations to determine the …
-
Have the OECD Transfer Pricing Guidelines influenced the development of domestic legislation for transfer pricing and the outcome of court decisions in selected African states?
… soft law instrument that acts as a guide to many multinational entities (MNE) in applying the arm's length principle (ALP). Amongst OECD member states, the OECD TPG is a relevant instrument to provide guidance to MNEs and Tax Administrations on how to apply the ALP. In transfer pricing legal …
-
Implementation of advanced pricing agreements by the South Africa Revenue Service: a critical review
… may be described as the process by which related entities set prices at which they transfer goods or services between each other. Multinational entities (MNEs), by virtue of its global presence, are subject to different tax laws of different countries. Accordingly, MNEs can potentially set …
-
A critical analysis of SARS' implementation of Advance Pricing Agreements
… The increase in cross-border transactions by multinational enterprises due to globalisation and internationalisation has increased the complexity of these transactions. This has resulted in lengthy and costly dispute resolution processes that pose uncertainty for multinational enterprises when …