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 118 for “"Tax Law"”.
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The Concept of 'Employment' In Employment Tax Law
THE CONCEPT OF ‘EMPLOYMENT’ IN EMPLOYMENT TAX LAW Guy Mulley Faculty of Law, University of Cambridge The tax status of differing kinds of personal labour is a contested area of UK law. At its root, tax status is about whether a working individual is or is not in ‘employment’ and thus about which of …
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‘Tax exceptionalism': a South African tax law perspective
… in statutory interpretation when it comes to tax law? This is the crux of the concept ‘tax exceptionalism', the misconception that tax law is fundamentally different and therefore should not be governed by the same rule of statutory interpretation that generally apply in the interpretation of …
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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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Estoppel and Substantive Legitimate Expectation in South African Tax Law
… to explore the legal avenues that may be open to taxpayers for holding the South African Revenue Services ('SARS') to the representations which it makes to the public in the form of general statements and specific rulings or directives. These avenues lie in two areas of law, namely the doctrine of …
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The Interpretation of Bilateral Tax Treaties: Changing Tax Law – Unchanging Treaty Obligations?
… central features of model-based bilateral income tax treaties. It does so through extensive analyses of principles for temporal treaty interpretation drawn from international law, and as enumerated in the Vienna Convention on the Law of Treaties (1969), as well as legal sources and interpretive …
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Beneficial Ownership and the Attribution of the Res in UK Tax Law
In UK tax law, the beneficial ownership concept is an important method of attribution which connects a *res* to an owner for the purposes of tax law. The title of this thesis may be broken down into four components: 1) beneficial ownership; 2) attribution; 3) *res*; and 4) UK tax law. This thesis …
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A comparative analysis of the concept of fiscal jurisdiction in income tax law
… rules of fiscal jurisdiction as well as the tax consequences resulting from the application of these rules, as implemented in the national tax law of the chosen jurisdictions. In essence, there are two main rules, which give content to the chosen theory of fiscal jurisdiction, mainly source …
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Challengers posed by electronic commerce to certain traditional concept in international tax law
… on certain aspects of international fiscal law. To give a more balanced perspective, I decided to add a section on other direct fiscal implications of electronic commerce, particularly from the perspective of fiscal administrations. The paper is therefore divided into two sections. Had I …
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Interpretation of fiscal statutes by the courts: a South African tax law perspective
This study examines the way in which the South African judiciary approaches the interpretation of fiscal legislation. It refers back to the use of the literal/textual approach (traditional approach), its shortcomings and the modification of such approach if it leads to absurdity. It also explores …
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Piercing the corporate veil: a review of the concept and considerations of its relevance in South African tax law
… the corporate veil is relevant in South African Tax Law. The first part of the paper is introductory in nature and is devoted to reviewing the concept from a company law perspective. Part I thus focuses on the following areas: • limited liability - rationale for; history and development, and …
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Piercing the corporate veil: a review of the concept and consideration of its relevance in South African tax law
… the corporate veil is relevant in South African Tax Law. The first part of the paper is introductory in nature and is devoted to reviewing the concept from a company law perspective. Part I thus focuses on the following areas: 0 limited liability - rationale for; history and development, and …
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The contribution of Judge Oliver Deneys Schreiner to the development of South African Tax Law : a mark that cannot be erased
… contribution to the development of South African tax law during his career on the bench. Not only did he make a substantial contribution to the development of South African tax law, but in my view he also a played a humble and selfless and indeed noteworthy role in the growth of our Nation's …
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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
… 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 and perceived …
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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
… 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 of the source principle in both inward and outward investment. This thesis attempts to discuss these …
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Mokesčių teisė: bendrosios teisės teorijos aspektai /
SUMMARY The fundamental conceptions of the tax law are analyzed in the Master’s Thesis “Tax Law: the aspects of the common law theory“. The objective of the Master’s Thesis is to describe and analyze the legal norms, regulating public relations related to taxes, in their entirety using categories …
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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
… comprising 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 …
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The 'pay now argue later' principle in South African Tax Law: its development, operation, comparison to South African civil debt enforcement and consistency with the constitutional right of access to courts
Section 164 of the Tax Administration Act 28 of 2011 (the TAA), previously contained in section 88 of the Income Tax Act 58 of 1962 (the Income Tax Act) and section 36 of the Value-Added Tax (VAT) Act 89 of 1991 (the VAT Act), provides that the payment of tax will not be automatically suspended …
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Penyanderaan (gijzeling) terhadap wajib pajak pribadi yang tidak kooperatif: Perspektif UU nomor 19 tahun 2000 jo UU nomor 19 tahun 1997 tentang penagihan pajak dengan surat paksa dan hukum Islam
… kewajibannya melunasi utang pajak. ENGLISH: Taxation in Indonesia uses the Self Assessment System that gives full credence to the taxpayer to calculate, deposit and report tax obligations. Self Assessment System allows the potential of the taxpayer does not pay off the tax obligations. …
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An investigation of the effects of complexity in federal income tax laws on the compliance of nonresident students
… the impact of complexity in federal income tax laws on taxpayer compliance. The primary research question is: Is complexity in the tax law associated with noncompliance? The research is unique in that previous work has not yet demonstrated an a priori circumstance in which taxpayers do not …
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