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Showing 1 to 4 of 4 for “"South African Gaar"”.
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Will the steps taken by South African expatriates to circumvent section 10(1)(o)(ii) trigger the South African GAAR?ar?
Background: Prior to 1 March 2020, South African expatriates working abroad were exempt from paying tax in South Africa on remuneration earned abroad in terms of Section 10(1)(o)(ii) of the Income Tax Act No.58 of 1962 (referred to as ‘the Act’ from here forth). However, with effect from 1 March …
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Does the South African GAAR criteria of the "misuse or abuse" of a provision included in Section 80A(c)(ii) of the Income Tax Act add any value?
… mechanisms. One such mechanism employed in South Africa ("SA") is the use of General anti-avoidance Rules ("GAAR") found in s80A-L of the Income Tax Act No. 58 of 1962 ("ITA"). To combat certain shortcomings in this GAAR's predecessor and to stay abreast of international trends, for the …
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A critical analysis of three contentious elements of the South African general anti-avoidance rules
… analyses three contentious elements of the South African GAAR to enhance clarity in its interpretation and application. In Chapter 3, the focus is on the purpose requirement, investigating whether it pertains to the subjective purpose of the taxpayer or the objective purpose of the of the …
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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
… with the general anti-avoidance rule (hereafter "GAAR") found within S80A of the Income Tax Act 8 of 1962. In doing so, the author asked which areas of the Principal Purpose Test are vague and can be interpreted in light of the South African GAAR to assist with attributing a meaning to it. The key …