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Showing 1 to 6 of 6 for “"tax resident"”.
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Factors to be considered when establishing the place of effective management in a digital economy
South Africa applies a residence-based tax system and accordingly a legal person or company is regarded as tax resident in South Africa if it is incorporated, established or formed in South Africa or if it has its place of effective management (POEM) in South Africa. Further, the POEM test is also …
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An analysis on taxation of South African residents who are employed and working outside the territorial borders of South Africa
… and I am often faced with questions on the tax treatment of employed individuals working abroad. It is for this reason that I have chosen to dedicate my research in this area. South African tax legislation on the exemption of foreign employment income has been amended with effect from 1 …
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The double tax consequence of the new double tax treaty between South Africa and Mauritius for persons other than individuals
… (FDI) and is well known for its favourable tax regime. This favourable tax regime remains one of the key reasons why South Africans use Mauritius as a preferred jurisdiction, well suited for passive investments as well as being an investment hub to establish and grow their foreign business …
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The taxation of 'Influencers' in South Africa and in an international context
… digital economy. However, existing international tax rules lack specific provisions addressing Influencers, raising questions about their tax treatment and the potential for treaty abuse. This underscores the necessity of exploring how the Influencers are to be taxed within the current legal …
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Exit taxes in the context of double tax treaties: is the individual emigrating from South Africa protected against double taxation?
… change of residence to another jurisdiction is a taxable event and may give rise to taxation of capital gains, based on a deemed disposal, even though there has not been an actual realisation of the capital gain. Such taxation is referred to as ‘exit or departure tax’ or ‘exit charge’. Double …
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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
… test often results in two rival claims regarding taxation based on residency. Prior to 2017, paragraph 3 of article 4 of the OECD Model expressed that a non-individual ‘shall be deemed to be a resident only of the State in which the “place of effective management” is situated.' In 2017, the term …