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 12 of 12 for “"OECD Model Tax Convention"”.
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An analysis of the Murabahah Islamic Finance Instrument in the context of article 11 of the OECD model tax convention on income and capital
Conventional banking and finance is based on interest-bearing loans or investments, or equity financing arrangements. Islamic banking and finance provides equivalent functionality to conventional finance except that the underlying arrangement is based on the trading of assets, profit and loss …
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South Africa's Restrictions on Interest Deductions and Their Compatibility with the Non-Discrimination Provisions of the 2017 Version of the OECD Model
… whether South Africa's interest deduction tax laws are compatible with selected aspects of their Double Taxation Treaties that are based on the 2017 OECD Model Tax Convention. This dissertation will outline and examine the innerworkings of three of South Africa's domestic interest deduction …
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A comparison of the substantive aspects of impermissible tax arrangements under South Africa's General Anti-Avoidance Rule and the Principal Purpose Test with specific reference to the examples found within the 2017 OECD Model Tax Convention
… Cooperation and Development released the 2017 Model Tax Convention on Income and on Capital (hereafter "Convention") which contains a Principal Purpose Test under article 29(9). The practical application of this test is explained with the use of various examples within the accompanying …
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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
… of crypto asset transactions has brought their tax implications into focus. This thesis explores whether returns from Decentralized Finance (DeFi) transactions, particularly staking activities, can be classified as interest for tax purposes under South African law and international tax treaties, …
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Evaluation of the "source " rules as contained in section 9 of the South African Income Tax Act as relating to software in the context of the digital economy
… above, there is a general move globally to align taxation with economic substance and value creation and there is an increased focus on source-based taxation. Consequently, this dissertation conducts an analysis of the relevance and appropriateness of South Africa's source rules pertaining to …
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The OECD transfer pricing guidelines: an analysis of their application in the South Africa legal regime
The provisions of S 31 of the Income Tax Act 58 of 1962 governing certain cross border transactions amongst entities form the basis of transfer pricing legal regulatory regime in South Africa. The arm's length principle forms the backbone of applying the provisions of the section. The existing …
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The OCED transfer pricing guidelines: an analysis of their application in the South Africian legal regime
The provisions of S 31 of the Income Tax Act 58 of 1962 governing certain crossborder transactions amongst entities form the basis of transfer pricing legal regulatory regime in South Africa. The arm's length principle forms the backbone of applying the provisions of the section. The existing …
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The legal status of memoranda of understanding in relation to treaties for the avoidance of double taxation and information exchange
… status MOUs have in the context of international tax law, particularly in relation to treaties for the avoidance of double taxation and information exchange has, to a greater extent, not been asked or answered in academic literature. This minor dissertation seeks to address that. Based on a review …
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The impact of e-commerce on the permanent establishment definition
… of a permanent establishment in a double tax agreement is to set out the type and permanency of business activities that an entity must conduct before they can be subject to tax in another jurisdiction. Furthermore, the definition of a 'permanent establishment' as defined in article 5 of …
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Information exchange across borders and confidentiality rights of taxpayers from a South African perspective
In light of the provisions of the Tax Administration Act, No 28 of 2011 (TAA), as well as the introduction of Tax Information Exchange Agreements (TIEAs) between South Africa and other nations around the world, the issues around information exchange and the confidentiality thereof has become …
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Domestic deeming provisions and double tax treaties: lessons from Tradehold and Fowler
… deeming provisions in South African domestic tax law and double tax treaties (‘DTTs'), focusing on the legal and interpretative challenges that arise when statutory fictions are applied within an international tax framework. Using a comparative analysis of Commissioner for the South African …
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Beteiligung an einer intransparent besteuerten ausländischen Personengesellschaft als steuerliches Gestaltungsinstrument
… Arbeit ist es, auf der Grundlage des OECD-Musterabkommens für einen in Deutschland unbeschränkt einkommensteuerpflichtigen Gesellschafter die steuerliche Behandlung einer Beteiligung an einer ausländischen intransparent besteuerten Personengesellschaft zu untersuchen. Auf der Grundlage …