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 44 for “"South African Revenue Service"”.
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Fostering the effectiveness of reportable arrangements provisions by enhancing digitalisation at the South African Revenue Service
Maladministration at the South African Revenue Service (SARS) resulted in the loss of public trust and negative implications on voluntary tax compliance and may encourage taxpayers to partake in aggressive tax planning schemes. This maladministration also resulted in the degeneration of SARS …
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An analysis of South African Revenue Service powers to request relevant material as it pertains to the so-called ‘lifestyle questionnaire’.
This study focuses on the South African Revenue Service’s (SARS) powers to request “relevant material” as it pertains to the so called ‘lifestyle questionnaire”. It also deals with taxpayer’s rights in terms of the Tax Administration Act No. 28 of 2011 (TAA) and the Constitution of the Republic of …
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The role of administrative justice in the realm of the commissioner's discretionary decisions as provided for by the Tax Administration Act 28 of 2011
The South African Revenue Service (“SARS”) is an organ of state in terms of the South African Revenue Service Act. SARS is mandated to administer the collection of tax The Commissioner for the South African Revenue Service (“CSARS”) is granted certain discretionary powers. This study focuses on two …
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Analysis of cryptocurrency verification challenges faced by the South African Revenue Service and tax authorities in other BRICS countries and whether SARS’ powers to gather information relating to cryptocurrency transactions are on par with those of other BRICS countries
… data challenges and determining whether South Africa could learn from the solutions implemented by these countries. The information gathering powers of SARS were also examined in order to determine whether those powers are on par with those of the BRICS’ countries. The findings suggest …
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"Expenditure"
… to analyse the case Commissioner for the South African Revenue Service v Labat Africa Ltd and its consequences in order to conclude whether the tax law created by the court is sound. Specifically it looks at the progression of the case through the different courts, as well as the other …
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The General Anti Avoidance Provisions, as amended
… Avoidance rules (GAAR) have been put in place in South Africa as a means to combat impermissible avoidance arrangements and collect what is actually due to the South African Revenue Service (SARS). The crux of GAAR thus rests on the fact that the taxpayer has engaged in an avoidance arrangement, …
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An analysis of the proposed annual mark-to-market taxation of the capital gains of long-term insurance policyholders
… is understood to be the collection by the South African Revenue Service (SARS) of capital gains tax (CGT) which has been 'effectively withheld' from policyholders by the insurer. Having gained an understanding of the mark-to-market proposal and its intended purpose, the proposal will be …
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Tax implications for business rescues in South African Law
The South African Revenue Service has in the past had difficulty in applying debt forgiveness in cases of corporate and business rescues. Taxation legislation was drafted to counter innovative section 311 schemes of arrangements where the sole purpose was to obtain maximum taxations benefits in …
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Value-added tax on electronic services : a study of the South African tax model
… guiding principle, the Commissioner of the South African Revenue Service (SARS) is mandated to collect all tax that is legally payable. This should be done in the most efficient and effective manner, which creates certainty for the taxpayer, reduces the likelihood of tax leakages as far as …
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Domestic deeming provisions and double tax treaties: lessons from Tradehold and Fowler
… between domestic 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 …
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How are professional football player transfers taxed in South Africa
… of Professional Sports Clubs and Players, the South African Revenue Service (“SARS”) states that it is unlikely that professional soccer clubs could be said to trade in player contracts, and accordingly, player transfers are unlikely to constitute revenue receipts or expenditure as anticipated …
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Characterisation for treaty purposes of manufactured dividends received in terms of securities lending arrangements
… governed by Article 10 of a double tax treaty, South Africa may not have the 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 …
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An analysis of paragraph (c) of the 'gross income' definition and the term 'services rendered'
The South African tax system operates as a dual system of direct and indirect taxation. Direct taxation is imposed directly on taxpayers be they natural or legal by nature, by imposing tax on the income of those taxpayers. This is known as income tax. Another form of direct taxation is estate duty. …
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The determinants of tax evasion amongst small and medium - sized enterprises (SMEs): Evidence from Limpopo Province, South Africa
… developing nations. It is widely practiced in South Africa, weakening the government's primary funding source for public spending. This study sought to pinpoint the primary factors that impact tax evasion in Small and Medium-Sized Enterprises located in Limpopo Province, South Africa. A …
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A critical assessment of the capital gains tax as a fiscal policy tool for South Africa
… the tax on capital gains as an addition to South Africa's fiscal framework. The method of the analysis involves the collation of international research on the effects of capital gains tax on the economies, financial markets, labour markets and revenue authorities of various countries. The …
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The Brummeria judgment: a comprehensive discourse on this case and its application to interest free loans granted to trusts
In September 2007, the world of South African tax planning received an unexpected judgment in the income tax case of the Commissioner for South African Revenue Service v Brummeria Renaissance (Phj) Ltd and others2. The reason why the decision in this case caused much controversy was because it ran …
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Farming and manufacturing: The tax consequences of conducting these activities simultaneously
… activities respectively, and it appears that the South African Revenue Service (SARS) applies an arbitrary practice in determining whether, and if so, at what point a farming operation needs to be distinguished from manufacturing activities. This dissertation explores how and when a taxpayer is …
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A critical analysis of SARS' implementation of Advance Pricing Agreements
… of advance pricing agreements (APAs) by the South African Revenue Service (SARS). Specifically, the transfer pricing legislation of selected foreign countries that implemented APAs as well as the Organisation for Economic Corporation and Development (OECD) transfer pricing guidelines were …
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An analysis of the current framework for the exchange of taxpayer information, with special reference to the taxpayer in South Africa's constitutional rights to privacy and just administrative action
Internationally, as well as in South Africa, legal reform aimed at increasing taxpayer information transparency has gained momentum over the past few years, especially in the light of the G20 led Base Erosion and Profit Shifting ('BEPS') Project. Ensuring that the fundamental rights of the …
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