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 7 of 7 for “"dividends tax"”.
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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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Does the proposed dividends tax overcome the international tax flaws that secondary tax on companies may have, namely exclusion from the scope of some double tax agreements and violation of the anti-discrimination provisions embodied in the OECD mode
Secondary tax on companies (STC) and the new dividends tax and its exemptions therefrom could be in contravention of the non-discrimination provisions of Article 24(5) of the OECD MTC. This question has not been decided in a South African court. This dissertation proposes the resolution to this …
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The availability of treaty relief for secondary transfer pricing adjustments taking the form of a deemed distribution of an asset in specie in South Africa
… recent years, putting a strain on international tax rules which have not developed at the same pace. Many of these MNEs have kept their tax bill at a minimum by shifting profits to low tax jurisdictions by using transfer prices that do not accord with economic reality. In response hereto, many …
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Characterisation for treaty purposes of manufactured dividends received in terms of securities lending arrangements
… shares to a borrower for a period of time. If dividends are declared during that period, these accrue to the borrower, and the borrower pays a manufactured dividend to the lender as compensation. The applicable income tax legislation deems manufactured dividends to be dividends for purposes of …
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Hybrid debt instruments: an investigation of intercompany instruments payable on demand in terms of section 8f. in partial fulfilment of the requirements for the degree master of commerce in South African taxation
Section 8F of the Income Tax Act, No. 58 of 1962, was introduced as an anti-avoidance provision and its recharacterisation rules came into effect in respect of amounts incurred or accrued on or after 1 April 2014. Where the ambits of this section are applied to an intercompany instrument, the …
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The suitability of the South African corporate tax regime for the use of South African resident intermediary holding companies
… of a group of companies. Investors have tax and non-tax reasons for conducting business using an IHC, and, depending on the reasons, they determine the location of the IHC based on the characteristics of potential host countries. This thesis analyses the suitability of the South African …
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An evaluation of South Africa's approach to tax avoidance through dividend stripping
Dividend stripping is a form of tax avoidance, a prevalent and universal problem in tax systems, originating from unavoidable tax law inconsistencies exploited by taxpayers. It entails the extraction of value from shares held in a target company by effectively selling the shares through tax-exempt …