Global ETD Search

International Tax Planning: The Concept of Place of Effective Management

Goosen, ChantelleDepartment of Commercial Law2014

This dissertation will study 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 …

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Factors to be considered when establishing the place of effective management in a digital economy

Augustin, NatalieDepartment of Finance and Tax2016

… or formed in South Africa or if it has its place of effective management (POEM) in South Africa. Further, the POEM test is also used as the 'tie-breaker' rule in double taxation agreements (DTA's), which are based on the Organisation for Economic Co-operation and Development Model Tax …

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1. When to cry, "Sham!" 2. Residence of a trust as defined by its place of effective management

Stephens, Anthea LouiseDepartment of Commercial Law2013

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Place of effective management' A comparison between the South African domestic tax concept and the International tax concept

Styane,TarrynDepartment of Commercial Law2009

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Residence of an Entity for Tax Purposes ' South Africa: A Review of the Concept 'Place of Effective Management'

Majachani, Alex FaraiDepartment of Commercial Law2010

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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

It is common for residency to be determined by place of incorporation or place of effective management (‘POEM'). As a result, the place of effective management test often results in two rival claims regarding taxation based on residency. Prior to 2017, paragraph 3 of article 4 of the OECD Model …

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Residence of a person other than a natural person for tax purposes in South Africa: the meaning of the concept 'place of effective management'

Paramaul, SerinyaDepartment of Commercial Law2013

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Place of effective management and "place of business" : a critical analysis of whether or not these phrases (as used in the Income Tax Act and Companies Act respectively) should be aligned or have different meanings?

Kriel, ElsabeDepartment of Finance and Tax2012

Includes abstract. Includes bibliographical references (leaves 65-70).

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Trading stock : a critical analysis of the application of Section 1 of the Income Tax Act no 58 of 1962

Nkerebuka, Eliya JohnDepartment of Commercial Law2015

… its residents to tax only on income arising out of a source within the borders of such a State. Under the international tax system, a State's right to tax firstly depends on whether the taxpayer deriving the said taxable income is a resident of that country or not. With respect to an entity or …

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Startups in South Africa, Barriers to Growth and Opportunity through Unconventional International Structures

Kelly, Timothy PeterDepartment of Commercial Law2022

… dealt with in this paper are in the context of and applicable to early-stage technology companies (“startups”). This paper discusses what a startup is and the relevance of startups in South Africa. It will further consider the challenges faced by startups in South Africa, particularly the …

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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

… ratified, accepted, and approved MLI and list of reservations and notification with the OECD on 30 September 2022. The MLI applies from 1 January 2023 in South Africa. In alignment with the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (“BEPS”) Action 6, South Africa has …

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