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 58 for “"Tax treatment"”.
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The tax treatment of losses arising in loans advanced
Our law recognises two types of loans, namely a loan for use (commodatum) and a loan for consumption (mutuum)'. In a loan for use something is delivered for use by a borrower without reward, and the borrower is obliged to return the same thing he received on loan. For example, a person may lend …
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The tax treatment of a financial instrument purchased by a trust
… for money borrowed and akin to rental in its treatment for tax purposes. As a result it has been considered to be a revenue expense which, provided has been actually incurred, in the production of income, for the purpose of the trade, is fully deductible. The main area of concern has been the …
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The tax treatment of interest incurred by mining companies to finance mining capital expenditure
This dissertation examines the tax treatment of interest incurred in financing mining capital expenditure. The capital expenditure under consideration is shaft-sinking and mining equipment. The reason for concern as regards this form of capital expenditure lies in the provisions of section …
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An analysis of the tax treatment of home office expenditure sought by salaried employees
… 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, various issues have been identified as to the …
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An analysis of the income tax treatment of South African collective investment schemes in securities
… of these findings identifies how the income tax treatment of such schemes differs, in law and in practice, from the tax treatment which would apply in the absence of any specific provisions in the Income Tax Act relating to these parties.
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Tax treatment of trade in cattle futures: possible implications to market efficiency and price stability
… for live cattle and feeder cattle futures. The tax treatment of speculative trades in the cattle futures markets has the potential to block participation of cattle feeders. To the extent that cattle feeders are effectively blocked from trading in futures in any capacity other than trades that …
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Tax treatment of trade in live cattle futures using a mean variance approach: implications to market efficiency and welfare changes
… for live cattle and feeder cattle futures. The tax treatment of speculative trades in the cattle futures markets has the potential to effective block participation of cattle feeders, however. To the extent that cattle feeders are effectively blocked from trading in futures in any capacity other …
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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
A constitutional 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 …
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An analysis of the income tax treatment of realised gains and losses from the use of short positions in South African hedge fund portfolio fundamental paired trades
… into the ambit of section 25BA of the Income Tax Act which carries an important distinction between amounts of a capital nature and amounts of a revenue nature. Given that hedge funds may use short positions for both profit-seeking and risk-mitigation purposes, the resulting proceeds from …
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Is the Value-Added-Tax treatment for educational services still valid?Is zero-rating a better alternative to the current VAT treatment?Are there any other alternative VAT treatments available?
… is to analyse whether the current VAT treatment for educational institutions is still valid given the development within these institutions and if not, to identify alternative VAT treatments that may be used. Educational services are an exempt supply under section 12(h) of the VAT Act. …
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An analysis on taxation of South African residents who are employed and working outside the territorial borders of South Africa
… and I am often faced with questions on the tax treatment of employed individuals working abroad. It is for this reason that I have chosen to dedicate my research in this area. South African tax legislation on the exemption of foreign employment income has been amended with effect from 1 …
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Corporate separations ; an analysis of their tax implications
… through a spin-off, split-off, or split-up. The tax treatment of a corporate separation is governed by Section 355 of the Internal Revenue Code of 1954, which allows the separation of two or more existing businesses to be tax-free provided certain requirements are met. This thesis discusses and …
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The normal tax treatment of cross-border dealings between various parts of a company in terms of the Income Tax Act, No. 58 of 1962, compared to selected aspects of the Organisation for Economic Cooperation and Development's Model convention on incom
Includes bibliographical references (leaves 147-151).
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The impact of the personal income tax on household health insurance coverage
… dissertation analyzes the effect of preferential tax treatment on household health insurance coverage in this country. Both employer-provided and individually purchased coverage are analyzed, with allowance for the possibility that a given tax filing unit may possess both types of coverage, and …
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A group income tax system for South Africa
This thesis establishes a group income tax system for South Africa so that equity may be achieved between the burden of company income tax borne by shareholders who invest in companies that are structured through subsidiaries and shareholders that invest in companies that are structured through …
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The tax consequences of the transfer of technical reserves between short-term insurers as part of a portfolio transfer
This dissertation focusses on the tax implications of a portfolio transfer between short-term insurers. The commercial purpose of a portfolio transfer is for one insurer (‘transferee') to effectively take over the insurance policies of another insurer (‘transferor'), with no negative impact on the …
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An analysis of the requirements for the imposition of securities transfer tax with specific focus on the securities transfer tax consequences of a repurchase of uncertificated shares
… STT outcomes. There is currently no uniform tax treatment of a share repurchase and legal commentators and SARS have divergent views on the mechanics of a share repurchase. In particular, there is no certainty whether a repurchased share is cancelled in the shareholder’s hands due to its …
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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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OPTIMISATION MODELS FOR CORPORATE TAXATION IN CAPITAL BUDGETING
… of investment decisions, financing methods and tax strategy for capital budgeting, taking into account tax-induced interactions between cash flows. The tax treatment of finance leases and the corporate group tax relief provisions are included. Shareholder risk considerations are taken into …
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The taxation of 'Influencers' in South Africa and in an international context
… digital economy. However, existing international tax rules lack specific provisions addressing Influencers, raising questions about their tax treatment and the potential for treaty abuse. This underscores the necessity of exploring how the Influencers are to be taxed within the current legal …
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