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 23 for “"permanent establishment"”.
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The impact of e-commerce on the permanent establishment definition
… object of the concept of the definition of a permanent establishment in a double tax agreement is to set out the type and permanency of business activities that an entity must conduct before they can be subject to tax in another jurisdiction. Furthermore, the definition of a 'permanent …
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Does the Permanent Establishment article give Namibia adequate taxing rights?An analysis of tax convention models in the mining and fishing industries
… double tax agreements to determine whether the permanent establishment article offers sufficient protection for Namibia’s source taxing rights with reference to Namibia’s largest and most important industries of fishing and mining. The permanent establishment article is of particular importance …
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Technical analysis of the creation of a permanent establishment for a non-resident employer by virtue of its employees working remotely from another country
Remote working is certainly no new phenomenon; it has only become more prevalent because of the COVID-19 pandemic. Remote working became possible with the development of the telephone, internet, laptops and smart devices, and allows employees not to be confined to their employer's workplaces. It is …
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The creation of a permanent establishment in South Africa as a result of the activities or presence of a partner or partners in South Africa
… Africa creates (or is at risk of creating) a permanent establishment for that partner, the partnership or the co-partners in South Africa. At the outset, the major legal and fiscal consequences of a partnership under South African law are investigated. The unique legal and fiscal treatment of …
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Does South Africa have a coherent policy for source-based taxation based on the permanent establishment concept, and how has this policy been implemented in its bilateral tax treaties?
The difference between South Africa’s domestic PE definition and the PE definition in its various DTCs and regional MTCs suggest some material inconsistency in South Africa’s PE policy. The research question this minor dissertation seeks to answer is whether South Africa has a coherent PE policy …
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Trading stock : a critical analysis of the application of Section 1 of the Income Tax Act no 58 of 1962
… treaty rules have established that the permanent establishment concept be used to tax business profits. The permanent establishment becomes the minimum criteria for establishing that such an enterprise has an economic presence within the borders of the source State. In the presence of an …
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Is the definition of "permanent establishment" ("PE"), as used in the Double Tax Agreements ("DTA's") of selected Southern African Development Community ("SADC") countries, sufficient to protect their taxing rights over their natural resources?
This dissertation will determine whether or not the definition of a PE, as used in the DTAs of selected SADC countries, sufficiently protects the right these countries have to tax foreign companies or other non-resident taxpayers who use their natural resources profitably.
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Is the definition of "permanent establishment", as used in the double tax agreements of selected 'oil rich' central and North African countries, sufficient to protect the taxing rights on the natural resources of these countries?
Given the considerable increase in international trade over the past 40 years, particularly between Africa and the rest of the world, there is a risk that the developing African countries are being exploited by the developed countries. The key to this exploitation is the fact that Africa possesses …
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Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources?
… tests the sufficiency of the definition of permanent establishments (PE), as contained in the Double Tax Agreements (DTAs) of selected "fishing rich" African countries, in protecting their taxing rights over profits made by non-residents from fishing in the waters of their states. The …
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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
… Africa and attributable to the non-resident’s permanent establishment situated in South Africa. In terms of the Organisation for Economic Co-operation and Development Model Tax Convention ('OECD MTC’), a permanent establishment is defined as essentially comprising of a fixed place of business …
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A critical analysis of South Africa’s domestic nexus requirements for the taxation of cross-border services
… as a result of the long held notion of the permanent establishment as a nexus requirement for source taxation; in a world where global trade, especially in services, can be significantly conducted without the need to establish a prolonged physical presence in the state of source. This is …
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The Fight of the Century: The Regulation and Reform of Prizefighting in Progressive Era America
… at every stop, reformers sought to prevent the permanent establishment of prizefighting as a legitimate business, even as the fame of these fighters elevated the sport to the highest level of popularity that it had enjoyed to that time. The fundamental battle of prizefight reform pitted local …
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Characterisation for treaty purposes of manufactured dividends received in terms of securities lending arrangements
… fiscus where a non-resident lender has no permanent establishment in South Africa.
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A critical analysis of whether BEPS Action 1 resolves issues of source taxation
… the requirement of a physical presence under the Permanent establishment threshold. It is found that the proposals do not address the source issues and are also not based on sound tax policy. The proposal will be at odds with various tax policy principles such as neutrality, equity, and …
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Developing a foundation for a globally coordinated approach to the taxation of crypto-asset transactions
… may further challenge the role of the permanent establishment concept in determining taxing rights and contribute to base erosion. While such transactions may fall within the measures to tax the digitalised economy, the pseudonymous, decentralised nature of blockchain technology may …
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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
… another state’s economy without establishing a permanent establishment or fixed base. This phenomenon proved problematic, especially in developing countries who are large importers of services, in that the country paying for the services would not be in a position to tax these activities however …
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The Nexus of Taxation for Artificial Intelligence According to the Organization of Economic Cooperation and Development and United Nations Model Tax Conventions
… it may be possible for AI to constitute a Permanent Establishment (PE). The taxation of AI for business profits does not cover the deficit in tax revenue caused by the shift of employment income to business profits, through the replacement of human employees. AI is not included in the …
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An analysis of the alternatives to impose direct taxes on income from non-resident app stores
The debate on 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 …
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The impacts of climate change on the summerfruit industry with respect to insect pest incursions
… increase of tropical or sub-tropical insect pest establishments in areas with temperate climates such as New Zealand. The increased risk of these exotic insect pests establishments is likely to affect both native ecosystems and agricultural industries. The New Zealand summerfruit industry is the …
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