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Showing 1 to 3 of 3 for “"low-tax jurisdictions"”.

  1. The source of income from the sale of goods electronically: an analysis of the division of the taxing rights in cross-border solutions

    … in business processes over time. Traditional tax principles, domestic and international are reliant on some level of physical activity being performed in a country before the taxing right is granted. In the past, businesses required a level of physical presence in each country they operated …

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  2. Assessment of the purpose of South Africa's controlled foreign company rules

    … are anti-avoidance provisions designed to deter taxpayers from shifting their capital (and resultant income) to low-tax jurisdictions. Adoption of these rules in South Africa coincided with the relaxation of exchange control laws which opened up borders to inward and outward capital flows. South …

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  3. 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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