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Showing 1 to 20 of 40 for “"South African income tax"”.
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Transfer Pricing in South African income tax law
… will remain, the most important international tax issue facing MNEs.' The term 'transfer pricing' is used to describe 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 …
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Tax avoidance provisions of the South African Income Tax Act
My thesis is on tax avoidance provisions in South Africa. I want to present an overview of tax avoidance in South Africa but I will concentrate more on section 103(1) which is the general anti - tax avoidance provision in South Africa.I will then proceed to look at the artificial tax avoidance, and …
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Investors' deductions and allowances in film funds : German and South African income tax laws compared
By comparing the income tax allowances and deductions for private investors in film production funds in Germany and in South Africa, the author aims to show how the governments of these two countries are taxing private individuals who invest in film funds, i.e. what incentives are offered to such …
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Bitcoin Mining under the South African income Tax Act: a case for a common treatment
… from the 1st October 2001, the basis for taxation in South Africa was fundamentally amended by virtue of the introduction of the Eighth Schedule as the embodiment of a tax regime based on the Haig-Simons comprehensive model of income. It is known as ‘Capital Gains Tax', or CGT, the tax …
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An analysis of the anti-avoidance provisions contained in the South African Income Tax Act
The South African Income Tax Act No 58 of 1962 contains a number of specific as well as general anti-avoidance provisions. This dissertation places its main emphasis of focus on-the general anti-avoidance provisors contained in section 103 of the Act
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An analysis of the anti-avoidance provision S.103 of the South African Income Tax act
The South African Income Tax Act contains a number of specific anti-avoidance sections, as well as a general anti-avoidance section. This dissertation will focus on the general anti-avoidance section 103 of the Income Tax Act No. 58 of 1962 and highlight the individual requirements and their …
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An analysis of the anti-avoidance provision section 103 of the South African Income Tax Act 58 of 1962
… their cases may fall outside the scope of the Taxing Acts. They incur no legal penalties and strictly speaking, no moral censure if, having considered the lines drawn by the legislature for the imposition of taxes, they make it their business to walk outside them."1 However, the South African …
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The deductibility of interest expenditure in leveraged buyout transactions under South African Income Tax Law : a critical examination of recent developments
… twofold: first, to provide an overview of the South African tax law principles governing the deductibility of interest expenditure incurred by taxpayers in respect of LBO transactions, as altered by the recent changes to the Act, and secondly, to critically consider and comment on the nature …
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The source of income in South African income tax law and the inward and outward structuring of investments into and out of South Africa
South Africa will shortly be a full member of the international community. This will result in both inward and outward investment. The South African income tax system is · based on the source of income. There is a limited reliance on the residence principle. It is essential to understand the scope …
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The fourth industrial revolution and South African income tax: an investigation into the exigencies placed on the tax and legal environment by crypto asset airdrops
… framework of what constitutes a good system of taxation is the notion that it should be characterised by simplicity and certainty, both in the substance of the law and the manner in which tax subjects are required to comply. By its nature alone taxation is complex due to it being necessarily …
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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
… use of mobile and sophisticated software in South Africa without having a significant physical presence in the country. In addition, the characterisation of income from new software-related arrangements may be difficult to determine in this new economy. In response to the above, there is a …
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Reconciling the taxation of partnerships in South Africa relative to its legal recognition. Does South African income tax legislation adequately deal with the taxation of ordinary commercial partnerships?
… of this dissertation is to examine whether South Africa’s approach to the taxation of ordinary partnerships flows clearly from its legal recognition thereof, or whether further clarity is needed from South Africa’s fiscal legislation i.ii Background and research method Peculiarities inherent …
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Defining a royalty from a South African perspective for the purposes of the South African Income Tax Act and the South African application of its Double Tax Treaty network
The word "royalty" is used in South Africa's Income Tax Act No. 58 of 1962 ("TA") at various points. Although there is a general understanding on the meaning of a royalty, there is no official definition for this term which can be used throughout the ITA. Section 35 of the ITA provides the …
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Tax planning in the light of tax avoidance provisions in the South African income tax Act Section 103- as amended in the income tax Act No 36 of 1996
… comes to one's mind, in dealing with question of tax planning and tax avoidance is, what is tax planning? What is its significance in the economy of each particular country? How does it affect every taxpayer and what consequences does it have for the Receiver of Revenue? Every country has got its …
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The relevance of the OECD BEPS action plan 2 recommnedations for selected aspects of cross border arbitrage through selected hybrid instruments and entity arrangements in South African Income Tax Law
… recommendations on domestic law and double tax convention measures. This dissertation assesses the potential implication of these recommendations for South Africa's tax laws and double tax conventions as these relate to cross border financing arrangements between two taxpayers using hybrid …
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Tax avoidance and tax reduction within the framework of the South African income tax legislation, with special reference to the effect on the fiscus and to current anomalies and inequities
The subject of tax avoidance and tax reduction within the framework of the income tax legislation has so far not been dealt with in any work in South Africa and this is, therefore, the first work of its kind. My approach in this work has generally been, firstly, to set out the effect of the law in …
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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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The general anti-avoidance section: a comparative analysis of Section 80a of the South African Tncome Tax Act no. 58 of 1962 and Section 35 of the Tanzanian Income Tax Act no. 11 of 2004
… of the general antiavoidance section of the South African Income Tax Act no. 58 of 1962 and the Tanzanian Income Tax Act no. 11 of 2004. The focus is on how the two provisions are interpreted by showing the similarities and differences. The approach will be analytical and comparative, …
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The commonalities or divergence of the meaning of beneficial owner in a treaty (International) and domestic context by Tasneem Koorowlay.
… “beneficial owner” was introduced into the South African Income Tax Act in April 2012 following an intention to align South African tax as regards dividends with international norms. The concept is applied in a domestic context by various countries and in numerous bilateral tax treaties and …
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