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 56 for “"Non-Resident"”.
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The taxation of non-resident entertainers and sportspersons
… tax base. As we are dealing with the taxation of non-residents in South Africa, the focus of this paper is within the realms of international law, specifically dealing with international tax practice. There is no international tax act governing International tax practice, as such it is more …
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The Taxation of International (non-resident) Sportspersons in South Africa
… tax inapplicable in many cases when applied to a resident of a Contracting State. Naturally the misalignment has no influence on sportspersons from States that have not concluded a DTA with South Africa. The misalignment has also been replicated in the concessionary legislation promulgated for the …
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The relationship between NWEA scores of resident and non-resident students
… (NWEA) scores of school of choice students and resident students. Background factors were also considered in the study, with focus on grade, gender, race, and special education and socioeconomic status of the students. The study included 5,975 students from 14 school districts in one Michigan …
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A Study Of Retention Rates Among Non-Resident Students Enrolled In Freshman Retention Programs
… freshman retention programs, cohort-based and non-cohort based freshman year experience (fye) courses, and the retention of academically less-prepared, non-resident students at a Southern University (SU). Structured interviews with open-ended questions were conducted for the qualitative …
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Fathers as co-parents: how non-resident fathers construe family situations after divorce or separation
… points over a year, to a cohort of separated, non-resident fathers from Strathclyde (n=17) still in contact with their children. The results were analysed using construct content categories developed for this research, inter-element distance measures, and asymmetric coefficients to assess …
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An analysis of the alternatives to impose direct taxes on income from non-resident app stores
… South Africa may only tax the income from non-resident app stores when a PE is created in South Africa by the non-resident. However, the tax planning structure and intangible nature of the internet app store enables non-resident platform providers and developers to sell apps and digital …
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Technical analysis of the creation of a permanent establishment for a non-resident employer by virtue of its employees working remotely from another country
Remote working is certainly no new phenomenon; it has only become more prevalent because of the COVID-19 pandemic. Remote working became possible with the development of the telephone, internet, laptops and smart devices, and allows employees not to be confined to their employer's workplaces. It is …
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The long arm provisions of capital gain tax: An analysis of the capital gains tax consequences on the indirect disposal of immovable property by non-residents in selected African Countries
A non-resident who disposes of a direct interest in immovable property or an indirect interest in immovable property through the disposal of shares may be subject to capital gains tax in the country in which the immovable property is situated. Certain African countries were selected and the capital …
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An analysis of income from staking crypto assets paid to a non-resident in terms of the South African Income Tax Act No. 58 of 1962, and a tax treaty established on the OECD Model Tax Convention
… Section 24J of the Income Tax Act provides a non-exhaustive list of items considered as interest in relation to financial and lending arrangements, with the underlying principal in common law being that interest is compensation for the advancement of credit. Interestingly, across the …
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Essays on the housing market
… between exchange rate depreciations and foreign non-resident investment in the housing market. I show that foreign non-resident transactions increase following exchange rate depreciations and are also increasing in the size of the depreciation. I find no evidence of similar effects for foreign …
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A critical analysis of the taxation of cross-border service fees in South Africa: Motivation for the reinstatement of the withholding tax on service fees
… The tax base erosion typically occurs when a non-resident derives a service fee from South Africa which is not taxed in South Africa, whilst the resident payor is allowed to claim a deduction. As a means of addressing the above threat, South Africa introduced the withholding tax on service …
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Parameters of undergraduate gambling
… a significant relationship to male gender, non-residency status, being over 21 years-old, and getting drunk often. The DSM-III-R, proposed DSM-IV, and the SOGS criteria measured pathological gambling at 5.1%, 4.2%, and 11.2%, respectively. No relationship was found linking the subjects' …
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Divorced co-parenting in rural communities: Understanding perceptions of parental quality from a socio-cognitive-behavioral perspective
… communication and low co-parenting satisfaction. Resident parents had stronger beliefs about expectations as well as greater satisfaction with their co-parenting role when compared with non-resident parents. Recommendations are to investigate reasons that differences exist between resident parents …
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Does a mineral right constitute 'immovable property' for purposes of the Income Tax Act and double tax treaties?
… 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 the case of the …
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Is the definition of "permanent establishment" ("PE"), as used in the Double Tax Agreements ("DTA's") of selected Southern African Development Community ("SADC") countries, sufficient to protect their taxing rights over their natural resources?
… countries have to tax foreign companies or other non-resident taxpayers who use their natural resources profitably.
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A proposed interpretation of the phrase "subject to tax" in section 23M(2)(i)(aa) of the Income Tax Act, No 58 of 1962, when read in context of South African Tax Treaties
… the corresponding interest income accrued to non-resident creditor is, among other things, (which is most important,) not ‘subject to tax' in terms of section 23M(2)(i)(aa) of the Act. However, despite its importance, the phrase ‘subject to tax' is not defined in section 23M or in the general …
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Characterisation for treaty purposes of manufactured dividends received in terms of securities lending arrangements
… right to tax manufactured dividends received by non-resident lenders. This would result in a loss of revenue for the South African fiscus. This paper examined the qualification or characterisation for treaty purposes of manufactured dividend income earned by lenders in terms of securities lending …
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Is the definition of "permanent establishment", as used in the double tax agreements of selected 'oil rich' central and North African countries, sufficient to protect the taxing rights on the natural resources of these countries?
… seeking companies from these countries ('the non-resident entity'), seek to extract and exploit.
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