Global ETD Search
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Showing 1 to 6 of 6 for “"tax residency"”.
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Practical challenges in applying The Place of Effective Management Test for Tax Residency in the context of South Africa's Headquarter Company Regime
It is common for residency to be determined by place of incorporation or place of effective management (‘POEM'). As a result, the place of effective management test often results in two rival claims regarding taxation based on residency. Prior to 2017, paragraph 3 of article 4 of the OECD Model …
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Will the steps taken by South African expatriates to circumvent section 10(1)(o)(ii) trigger the South African GAAR?ar?
… working abroad were exempt from paying tax in South Africa on remuneration earned abroad in terms of Section 10(1)(o)(ii) of the Income Tax Act No.58 of 1962 (referred to as ‘the Act’ from here forth). However, with effect from 1 March 2020, South African expatriates working abroad are …
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The international tax consequences arising on the death of South African individuals owning Greek or Portuguese property and Greeks or Portuguese owning South African property
South Africa levies two taxes on an individual in the event of death; namely estate duty and capital gains tax. Much debate exists on whether it is fair for South Africans to pay a "double tax" on the same assets on death. There is also a possibility that the deceased becomes liable for a third tax …
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A critical analysis of the impact of the MLI in the determination of corporate residency in South Africa: a synthesis of a hierarchy of factors to used for resolving dual residency under map
… 4(1) deals with the determination of corporate residency and modifies the existing tie-breaker rule in South Africa's Double Taxation Agreements (“DTAs”) to solving cases of dual residency through a Mutual Agreement Procedure (“MAP”). The MLI's approach of using MAP as a tie-breaker includes a …
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Startups in South Africa, Barriers to Growth and Opportunity through Unconventional International Structures
… discuss the interplay between transfer pricing, tax residency and intellectual property in the context of setting up a mirror structure. These elements considered together deal with the factors which need to be taken into account by a startup when immigrating the headquarters of a company to an …
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La fiscalitat en el comerç electrònic d'obres escrites en format digital i en paper, en el marc d'una activitat d'auto-publicació per part dels propis autors
… are considered from the point of view of taxation.