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 9 of 9 for “"South african resident"”.
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The suitability of the South African corporate tax regime for the use of South African resident intermediary holding companies
… This thesis analyses the suitability of the South African corporate tax regime for the use of South African-resident Intermediary Holding Companies. The South African government has the objective of promoting South Africa as a gateway for investment in Africa and for this reason the present …
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Potential Cross-Border Double Taxation on Death Limits Global Investment Opportunities for Long Term South African Resident Investors - demonstrated through an analysis of the international tax consequences that arise for a South African resident who holds an investment in a portfolio of stock listed in the United States of America at the date of death
… both estate duty and capital gains tax (CGT) by South Africa (SA) on South African resident investors at the date of death.1 The focus of this dissertation, within this chosen area of study, is the effect of the imposition of these two taxes on cross-border transactions; this study examines the …
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To what extent can a South African resident donor's offshore investment trust be arranged so as to avoid the following South African taxes and duty
… beneficiaries; some, or more of them, being South African residents. The report will also examine the ramifications for a South African donor and beneficiary from an income tax, capital gains tax, donations tax and estate duty point of view that will exclude a consideration of value added tax …
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Shortcomings of and recommendations to improve double taxation relief mechanisms: a study of South African resident companies engaged in the exploration for and production of oil and gas outside of South Africa
South African resident companies engaged in the exploration for and production of oil and gas outside of South Africa are subject to double taxation. This thesis evaluates whether South African resident companies engaged in the exploration for and production of oil and gas outside of South Africa …
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An analysis of the possible fiscal consequences of a controlled foreign company being declared resident in South Africa– may SARS have its cake and eat it?
… raised are as follows: suppose that Company A, a South African resident, owns 100% of the participation rights in Company B (the hypothetical taxpayer), a resident of Luxembourg. Company A has failed to qualify for any of the internal “exemptions”1 contained in section 9D of the Income Tax Act, 58 …
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A constitutional analysis of a differentiated tax treatment of residents and non-residents in respect of income deriving from immovable property in South Africa
… analysis of a differentiated tax treatment of residents and non-residents in respect of income deriving from immovable property in South Africa', Daniel Baines explores whether South African resident taxpayers' constitutional rights to equality and property are infringed by current laws which …
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Exit taxes in the context of double tax treaties: is the individual emigrating from South Africa protected against double taxation?
For some countries, such as South Africa, a change of residence to another jurisdiction is a taxable event and may give rise to taxation of capital gains, based on a deemed disposal, even though there has not been an actual realisation of the capital gain. Such taxation is referred to as ‘exit or …
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A technical analysis of the difference in treatment of technical fees in relation to the receipt of management fees by a resident of South Africa, sourced from Botswana and Zambia, including the impact of domestic and treaty relief
… law a tax on technical services paid to nonresidents. This is usually in the form of a withholding tax. This practice was undesirable for both taxpayers and tax authorities in that it resulted in unrelieved double taxation or double non-taxation which in turn causes difficult disputes whilst …
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A critical analysis of the taxation of interactive gambling income earned by resident South African individuals
… in the popularity of interactive gambling in South Africa due to the wide range of channels in which the public can now quickly and easily access gambling opportunities. Although there is uncertainty related to whether or not interactive gambling is considered to be legal in South Africa, the …