"Mutual Agreement Procedure (MAP)" · 2 results · Global ETD Search

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Showing 1 to 2 of 2 for “"Mutual Agreement Procedure (MAP)"”.

A critical analysis of the impact of the MLI in the determination of corporate residency in South Africa: a synthesis of a hierarchy of factors to used for resolving dual residency under map

Naamdhew, AkiraDepartment of Finance and Tax2025

… rule in South Africa's Double Taxation Agreements (“DTAs”) to solving cases of dual residency through a Mutual Agreement Procedure (“MAP”). The MLI's approach of using MAP as a tie-breaker includes a non-exhaustive list of criteria that tax authorities may consider as relevant. This …

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Practical challenges in applying The Place of Effective Management Test for Tax Residency in the context of South Africa's Headquarter Company Regime

Dumisa, SinenhlanhlaDepartment of Commercial Law2022

… States shall endeavour to resolve, by mutual agreement, cases of dual residence of a person other than an individual.' Most commentators interpret POEM as the point where key and commercial and strategic decisions are made. As such, a company headquartered in South Africa with a …

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