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 27 for “"South African Revenue Service (SARS)"”.
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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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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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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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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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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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An evaluation of the recourse available to taxpayers where SARS does not adhere to the correct tax administrative procedures
There is a common perception among South African taxpayers and tax professionals that the South African Revenue Service (“SARS”) is “draconian” in its administrative actions and interactions with taxpayers and tax professionals, which infringes on taxpayers’ constitutional right to just …
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Analysis of demographic, socio-economic and geographic factors affecting adoption and success of personal income tax e-filing in South Africa
… income tax returns is regarded as one of the South African Revenue Service (SARS)'s success stories based on its growth since its inception in 2006. Given the importance of tax revenue as a major source of revenue to government, this study explores the effects of personal income tax e-filling …
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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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Investigating the ability of taxpayers to determine the income tax consequences of cryptocurrency transactions in South Africa
In 2018, the South African Revenue Service (SARS) issued a media statement providing guidance for the first time to South African citizens on the taxation of cryptocurrency transactions. The SARS media guidelines indicate that the normal income tax rules of the South African Income Tax Act will …
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Tax consequences of the 2010 FIFA World Cup
With all the excitement in South Africa about the 2010 FIFA World Cup kicking off on 11 June 2010, tax relief will be granted on import tax and VAT, amongst others, in terms of the Revenue Laws Amendment Act 20 of 2006 (hereafter referred to as RLAA). FIFA (Federation Internationale de Football …
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An application of a model of public management reform to tax administration reform in South Africa
Since its statutory creation in 1997, the South African Revenue Service (SARS) has virtually unanimously been seen as a shining light of South African public administration due to its widely perceived efficiency and record of consistently and comfortably surpassing revenue collection targets. …
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Home Office Expenditure: A critical analysis of the applicable law governing the deductibility of home workspace expenses incurred by persons in employment - given the shift to working from home
… using the landmark Endumeni approach). The South African Revenue Service (‘SARS') has attempted to update the existing Interpretation Note (‘IN') dealing with home workspace expenditure, for which they released two drafts, both in 2021; and finalised such IN in 2022. Although SARS' …
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Income Tax – Sale of a going concern: Assumed Contingent Liabilities Clarification versus legislative reforms
… by National Treasury (Treasury) and the South African Revenue Service (SARS), and income tax legislation and case law that do not adequately recognise the economic effect of these transactions for sellers and purchasers. These, and other, challenges are highlighted and unpacked in this …
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The 1996 Constitution and the Tax Administration Act 28 of 2011 : balancing efficient and effective tax administration with taxpayers' rights
Taxation is fundamental for development in South Africa (SA), a developing country with an emerging economy in which taxation is essential to capacitate the government so that it can fulfil its mandate under the Constitution of the Republic of South Africa, 1996 (Constitution). This mandate …
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A comparative analysis of the meaning of 'mining operations' for income tax purposes
The South African ("SA") mining industry played (and continues to play) a pivotal role in the development of the SA economy. It is therefore no surprise that the industry has long been the beneficiary of favourable tax concessions. One of these favourable tax concessions is the 100% capital …
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An analysis of the tax treatment of home office expenditure sought by salaried employees
The South African Revenue Service (SARS) disallowed 60% of home office claims during the 2021 tax year. This is a consequence of the fact that the home office of these taxpayers did not meet the requirements of section 23(b) of the Income Tax Act No.58 of 1963 (IT Act). In this dissertation, …
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Transfer Pricing in South African income tax law
… arrangements involving the transfer of goods or services, at an artificial price, in order to transfer income or expenses from one enterprise to an associated enterprise in a different tax jurisdiction. This results in the income derived at for each enterprise being disproportionate to their …
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