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 9 of 9 for “"international tax law"”.
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Challengers posed by electronic commerce to certain traditional concept in international tax law
… fiscal regimes, both from a domestic and an international perspective. It is against this background that I elected to research and present a dissertation on the implications of electronic commerce on certain aspects of international fiscal law. To give a more balanced perspective, I decided …
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The scope for multilateral international co-operation in tax affairs / The tax and exchange control consequences of virtual currency transactions in South Africa
1. The scope for multilateral international co-operation in tax affairs: While some measures have been taken in the past to create some form of multilateral co-operation in respect of the enforcement of domestic tax laws, these have been limited either in scope or in scale, or both. This paper …
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Judicial review of revenue authority decisions in a specific tax treaty context – a study of the extent of convergence in the reasoning of different courts reviewing revenue authority decisions under model-based tax treaties
… of discretion under specific model-based tax treaty clauses that confer wide decision-making powers to officials. The aim is to identify whether there is convergence in argument that may be of relevance to other courts for the uniform interpretation of tax treaties. The research …
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A critical analysis of whether BEPS Action 1 resolves issues of source taxation
… economy and the challenges it poses to the international tax arena is a swiftly developing area. This dissertation considers the suggestions released by the OECD Pillar 1 dated January 2020 and the UN Article 12B released in August 2020. The digital economy has evolved significantly over the …
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Legal aspects of international tax planning for sportspeople and entertainers: a critical examination from a UK perspective, with comparative analysis from a US perspective, of the degree to which offshore financial centres can provide effective tools for international tax planning for sportspeople and entertainers
… thesis stated that academic research into international tax law was in its early stages of development. Today, with the increasing globalisation of finance, the growth in offshore financial centres and the unprecedented mobility of capital and labour, the need for such continued research is …
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The legal status of memoranda of understanding in relation to treaties for the avoidance of double taxation and information exchange
It has been suggested by international lawyers that Memoranda of Understanding (MOUs) are instruments concluded between States which they do not intend to be governed by international law (or any other law) and, as a result, are not legally binding. The question as to what legal status MOUs have in …
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TAX DISPUTES IN INVESTOR-STATE ARBITRATION
This thesis examines tax disputes adjudicated by investor-state tribunals. I argue that the nature of taxation – a compulsory levy – is unlike any other state regulatory measure such as an environmental or a public health measure. I suggest that tax-related investment disputes constitute a unique …
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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 …