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 16 of 16 for “"Withholding tax"”.
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A critical analysis of the taxation of cross-border service fees in South Africa: Motivation for the reinstatement of the withholding tax on service fees
… that South Africa implements laws that seek to tax service fees in an efficient, effective and equitable manner. South Africa’s Minister of Finance and the Davis Tax Committee are amongst the key government stakeholders who have expressed concern regarding the threat that South Africa faces to …
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The Taxation of International (non-resident) Sportspersons in South Africa
… the sportsperson article in South African Double Tax Agreements (DTAs), the withholding tax applied to sportspersons performing in South Africa is analysed against the sportsperson article to determine whether these are appropriately aligned. The interpretational rules applicable to fiscal …
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Withholding tax on services : a square peg in a round hole? : an analysis of intra-group cross border services in the context of source, related transfer pricing principles and witholding taxes
Various countries have extended the levying of withholding taxes beyond the traditional withholding taxes on royalties, dividends and interest. Withholding taxes are now often levied on services such as management services, professional services, technical services, financial services, insurance …
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A comparative analysis of the foreign tax credit system of South Africa, with specific reference to corporate taxpayers and technical service fees
… often resulted in increased instances of double taxation for South African corporate taxpayers, as a result of the fact that the majority of the jurisdictions in Africa apply a withholding tax on technical service income paid to nonresidents. The ability to claim relief for the juridical double …
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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
… for the services would not be in a position to tax these activities however would, in terms of application of their domestic laws, be required to provide a deduction in relation to the payment for services where it relates to legitimate costs incurred in the production of income. In light of …
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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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Is South Africa's headquarter regime successful and does it go against national legislation? Are rewards from a customer loyalty programme capital or revenue in nature?
Research paper 1. (International tax) Is South Africa's headquarter regime successful and does it go against national legislation. This research paper discusses how South Africa has changed its legislation to become the Gateway of investment into Africa. It addresses the prior barriers previously …
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Dividend tax changes and ex-dividend behaviour: the case of South Africa
In April 2012, South Africa changed its tax system on dividends. South Africa switched from using Secondary Tax on Companies (STC) to Dividend Withholding Tax (DWT) in an effort to align with the international standards and eliminate the perception of a higher tax rate. This paper attempts to …
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An analysis of the alternatives to impose direct taxes on income from non-resident app stores
… the appropriateness of the current international tax framework to address electronic commerce business models has been ongoing for almost two decades with little resolution on alternatives for reform. One of the recent business models to emerge in the last eight years was the internet app store. …
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Dividend payments from employee share scheme trusts
… the past, there has been confusion regarding the taxation of dividends received from employee share scheme trusts. Conflicting interpretations of the definitions in section 8C and certain provisions of 10(1)(k) of the Income Tax Act No. 58 of 1962 (ITA) have caused administrators of these schemes …
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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 …
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The long arm provisions of capital gain tax: An analysis of the capital gains tax consequences on the indirect disposal of immovable property by non-residents in selected African Countries
… of shares may be subject to capital gains tax in the country in which the immovable property is situated. Certain African countries were selected and the capital gains tax consequences on disposal of such property were determined by analysing the domestic tax legislation of the country in …
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A proposed interpretation of the phrase "subject to tax" in section 23M(2)(i)(aa) of the Income Tax Act, No 58 of 1962, when read in context of South African Tax Treaties
Following the tax policy recommendation of the Organisation for Economic Co-operation and Development (‘OECD')/Group of Twenty (‘G20') member countries, under the OECD/G20 Base Erosion and Profit Shifting Project: Action 4 (‘BEPS Action 4'), the South African legislature recently enacted an …
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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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Taxing of dividends : a transition from secondary tax on companies (STC) to dividends tax
No abstract available.
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European Private Equity-Fund for Entrepreneurs and the Impact on Market Growth within the Boundaries of the European Union.
… their activities. They are creating jobs, pay taxes and may help suppliers to gain new contracts. Unfortunately, it is not always made easy for entrepreneurs. The thesis „European Private Equity-Funds for Entrepreneurs and the Impact on Market Growth within the Boundaries of the European Union“ …