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 20 of 32 for “"profit shifting"”.
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A study of the democratic legitimacy of Action 13 of the OECD's base erosion and profit shifting (BEPS) Action 13.
… and Development's (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan. Taking a critically orientated philosophical position, the thesis draws data from a stakeholder consultation conducted by the OECD which is coded to allow statistical analysis. The thesis then goes on to collect …
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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?
… The overall effect of the structure is to move profits from a high tax jurisdiction through the interest payments to a low tax jurisdiction and thus reduce the multinational group's effective tax rate. This study focuses on how such a structure can arise in the South African tax system and if …
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Siezing the BEPS: an assessment of the efficacy of South Africa’s thin capitalisation regime in combating base erosion and profit shifting (BEPS) through excessive interest deductions
… framework in dealing with Base Erosion and Profit Shifting (BEPS) through excessive interest deductions by multinational enterprises (MNEs). Given the impact of globalisation in interconnecting economic activities across multiple countries, BEPS presents a major policy concern both …
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The possibility of base erosion and profit shifting through special economic zones: A critique of the South African and Kenyan SEZ regimes based on BEPS action 5
The OECD/G20's Base Erosion and Profit Shifting (BEPS) Project has been described as the most significant international tax initiative post the 2008/2009 global economic crisis. BEPS speaks to companies engaging in aggressive tax planning strategies that exploit loopholes in tax systems to make …
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Assessment of the purpose of South Africa's controlled foreign company rules
… 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 Africa's CFC …
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Interest limitation and thin capitalisation rules: an analysis of global practices and learnings for South Africa
… loses approximately R7 billion a year due to profit shifting by multinational corporations amounting to about 4% of the total corporate income tax receipts. It is estimated that 98% of this tax loss can be directly attributed to the profit shifting schemes of the largest 10% of multinational …
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Interest limitation and thin capitalisation rules: an analysis of global practices and learnings for South Africa
… loses approximately R7 billion a year due to profit shifting by multinational corporations amounting to about 4% of the total corporate income tax receipts. It is estimated that 98% of this tax loss can be directly attributed to the profit shifting schemes of the largest 10% of multinational …
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Essays on Tax Information Exchange in a Post-BEPS World
… is recent global cooperation on counteraction to profit shifting and base erosion. Extended and systematic tax information exchange is a key component of the cooperation. I employ the most advanced communication mechanisms, namely cheap talk and Bayesian persuasion, to model revelation, …
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An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective
… on its findings concerning base erosion and profit shifting ("BEPS").1 That report, in particular Action Plan 13, dealt with the re-examination of transfer pricing documentation wherein the shifting of profits to lower tax rate jurisdictions is addressed. The OECD proposed a …
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What are thin capitalization tax schemes and how are they being countered by policy makers.
… in order to avoid taxation and move profits across borders by providing an overview of the rules put in place to counter such behaviors and international steps being taken to further battle profit shifting as a way of tax avoidance. Finally, an explanation of their affects and how or …
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Pilari 2-hankke seuraava ratkaisu nykyverotuksen haasteisiin? - Yhdysvaltojen GILTI-hanke mahdollisena mallina
… 2 on osa OECD:n BEPS-hanketta (Base Erosion and Profit Shifting), joka pyrkii estämään yrityksiä siirtämästä voittojaan maasta toiseen veronkierron tarkoituksessa. Pilari 2:n tavoitteena on luoda globaali vähimmäisverokanta, joka koskee suuria kansainvälisiä yrityksiä ja minimoi verokilpailun …
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Seeking arm’s length: An evaluation of formulary apportionment and predetermined margins as alternative or supplementary methods to establish proxy arm’s length transfer prices for multinational intercompany transactions in South Africa
… tax revenue and the effects of base erosion and profit shifting on the financial well-being of the state (OECD:G20 Working group, 2014); (Economic Commissions for Africa, 2018). Section 31 of the South African Income Tax Act, is the main section in the Act relating to transfer pricing in South …
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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
… government towards the OECD's base erosion and profit shifting proposals and thereafter by assessing how the above noted recommendations may interact with the Income Tax Act and South Africa's double tax conventions to address mismatches within the scope of this dissertation. This interactions …
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Hvernig hafa ríki útfært CFC reglur í ljósi BEPS aðgerðaráætlunar OECD? Samanburður á löggjöf Íslands og Bandaríkjanna
… BEPS stendur fyrir Base Erosion and Profit Shifting sem hefur á íslensku verið þýtt sem rýrnun skattstofna og tilfærsla hagnaðar. Þar sem aðgerðaráætlunin hefur einungis að geyma leiðbeiningar um hvernig æskilegt væri að haga löggjöf er auk þess rýnt í hvernig bæði Bandaríkin og …
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Transfer pricing : an evaluation of section 31 of the Income Tax Act
… particularly vulnerable to base erosion and profit shifting by multinational enterprises.
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BEPS action 14 – the effectiveness of the dispute resolution proposals, with specific reference to South Africa
… proposed by Action 14 of the Base Erosion Profit Shifting (BEPS) Project. The BEPS Project' was introduced in 2013 by the OECD working together with the G20 and other states to reform the international tax framework. The reform was necessary to deal with the challenges posed by …
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An investigation into whether the South African and Mauritian preferential holding company regimes may undermine fiscal transparency
… of corporations so as to curb base erosion and profit shifting and to prevent fiscal losses arising from unintended deliberate abuse of double tax treaty benefits. This dissertation examines whether Africa's two favourable holding company regimes, the South African Headquarter Company and the …
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An analysis of the current framework for the exchange of taxpayer information, with special reference to the taxpayer in South Africa's constitutional rights to privacy and just administrative action
… in the light of the G20 led Base Erosion and Profit Shifting ('BEPS') Project. Ensuring that the fundamental rights of the taxpayer, guaranteed by the Constitution1, remain protected amidst the hurried implementation of these reforms is of paramount importance and cannot be overlooked or …
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Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector
… examines whether the OECD's Base Erosion and Profit Shifting ('BEPS') Action Plan 9 is an appropriate framework for MNE groups in the banking sector or whether it creates further challenges. Additionally, the dissertation scrutinises MNE groups in the financial sector that are involved in the …
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The taxation of trusts in South Africa: Critical analysis of Section 7C
… trends including the Base Erosion and Profit Shifting (BEPS) final reports. As globalisation accelerates and data becomes more readily available to both developed and developing economies the transparency of structures will become more evident and the previously utilised loopholes will …
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