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.
Results
Showing 1 to 8 of 8 for “"Tax Jurisdiction"”.
-
Are South Africa's section 23m interest limitation rules sufficiently targeted and effective in combatting base erosion and profit shifting through earnings stripping schemes by associated enterprises?
… one affiliate company resident in a low or no tax jurisdiction advances an intra-group loan to another affiliate member company resident in a high tax jurisdiction so that the latter makes excessive deductible interest payments. The overall effect of the structure is to move profits from a high …
-
Exploring challenges with transfer pricing in South Africa: impact on government spent and income
Transfer pricing is a challenge for tax collection as taxpayers in multinational corporations may shift profits from affiliates in high-tax jurisdiction to their lower-tax jurisdiction counterparts (for tax avoidance), leading to reduced tax collected and therefore the country's financial muscle …
-
A critical analysis of whether the current legislated exit tax provisions of South Africa are proportional to the legitimate purpose of those provisions
When a South African taxpayer transfers his/her residence to another tax jurisdiction, exit tax is levied on certain accrued gains on the basis that a termination of residency results in a deemed disposal. This creates a fiction that the taxpayer disposes of his/her assets even though there was no …
-
Privacy-Preserving Vehicle Miles Traveled (PPVMT) tax
Motor fuel taxes form a great part of the total revenue collected for the development and maintenance of surface transportation. Gasoline tax payments are becoming a matter of concern as the share of Battery Vehicles (BVs) increases in the market. Those funds need to be collected in some other way …
-
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 …
-
An analysis of the effect of the amendments to the taxation of foreign non-South African employment income
… a source based to a residence based system of taxation on 1 March 2001, all South African residents were now being subject to tax on their world-wide income. Residents working outside the Republic were then at risk of being taxed twice on the employment income derived because of South Africa’s …
-
Exit taxes in the context of double tax treaties: is the individual emigrating from South Africa protected against double taxation?
… 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 departure tax’ or ‘exit …
-
O arquétipo constitucional do ITBI possibilidades jurídicas da sua hipótese de incidência sob a ótica exclusiva da transmissão de bens imóveis
O objetivo do presente trabalho é investigar os limites da competência municipal para a instituição do ITBI – transmissão inter vivos, a qualquer título, por ato oneroso, de bens imóveis, por natureza ou acessão física, e de direitos reais sobre imóveis, exceto os de garantia, bem como cessão de …