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 7 of 7 for “"thin capitalisation"”.
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Interest limitation and thin capitalisation rules: an analysis of global practices and learnings for South Africa
… to the transferring or shifting of profits within a multinational group of companies from a firm in a higher‐tax‐rate country to an associated company in a lower‐tax‐rate country. It can be legitimate to some degree, however this practice by multinationals is increasingly becoming a challenge …
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Interest limitation and thin capitalisation rules: an analysis of global practices and learnings for South Africa
… to the transferring or shifting of profits within a multinational group of companies from a firm in a higher‐tax‐rate country to an associated company in a lower‐tax‐rate country. It can be legitimate to some degree, however this practice by multinationals is increasingly becoming a challenge …
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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
… assess the effectiveness of South Africa’s thin capitalisation 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 …
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Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions
… in South Africa to combat the practice known as "thin capitalisation". It critically analyses the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions: Thin capitalisation. It concludes that the arms-length approach is not suitable …
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Transfer pricing : an evaluation of section 31 of the Income Tax Act
… recent amendments, particularly with regard to thin capitalisation, have created a degree of commercial uncertainty for multinational enterprises. With regard to the South African context, this paper seeks to illustrate the increased compliance burden placed on South African taxpayers as a …
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The suitability of the South African corporate tax regime for the use of South African resident intermediary holding companies
… itself to anti-avoidance measures such as thin capitalisation and transfer pricing provisions. The existence of such taxes and anti-avoidance measures in the tax system of a country may deter investors from locating an IHC in such country. Exchange control regulations could also adversely …
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Is South Africa's headquarter regime successful and does it go against national legislation? Are rewards from a customer loyalty programme capital or revenue in nature?
… interest withholding tax, transfer pricing and thin capitalisation, exchange control and finally CFC rules. The advantage that South Africa has is that of their double tax agreements with Nigeria and Algeria. The research paper also addresses the extent to which headquarter regimes in South …