Does the proposed dividends tax overcome the international tax flaws that secondary tax on companies may have, namely exclusion from the scope of some double tax agreements and violation of the anti-discrimination provisions embodied in the OECD mode

Secondary tax on companies (STC) and the new dividends tax and its exemptions therefrom could be in contravention of the non-discrimination provisions of Article 24(5) of the OECD MTC. This question has not been decided in a South African court. This dissertation proposes the resolution to this question. The outcome of this research may be particularly relevant in the context of the proposed new dividends tax and value extraction tax (“VET”) and the exemptions therefrom, which are, again, based on residency.

Grantor dc:publisher.institution

Department of Commercial Law

Year dc:date.issued

2011

Author dc:creator

• Lovely, Graham

Advisor dc:contributor.advisor

• West, Craig

Language dc:language.iso

eng

Handle dc:identifier.uri

http://hdl.handle.net/11427/11135

OAI identifier oai:identifier

oai:open.uct.ac.za:11427/11135