Similar Items: Does South Africa have a coherent policy for source-based taxation based on the permanent establishment concept, and how has this policy been implemented in its bilateral tax treaties?
- Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources?
- The formulation of a coherent South African approach to the classification of income and the taxation of international cross-border partnerships
- The legal status of memoranda of understanding in relation to treaties for the avoidance of double taxation and information exchange
- A critical analysis of statutory deeming in the context of the interaction between South Africa's controlled foreign company regime and model-based bilateral tax treaties
- Foreign direct investment into Africa and the role of taxation : a case study of Ghana and Rwanda,with a focus on the influence of taxation incentive policies and regulations currently in force
- Seeking common deviations from South Africa’s tax treaty policy: a comparative analysis identifying trends (regional or otherwise) in treaty practice in bi-lateral tax treaties with countries in Asia, Australasia, North America and South America
Author: Hattingh, Johann
- 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
- South Africa's Restrictions on Interest Deductions and Their Compatibility with the Non-Discrimination Provisions of the 2017 Version of the OECD Model
- An analysis of the Murabahah Islamic Finance Instrument in the context of article 11 of the OECD model tax convention on income and capital
- An analysis of options for reform of South Africa’s unilateral income tax exemption of foreign pensions, with an emphasis on the cross-border interaction with pensions derived from the United Kingdom and Germany
- 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
- A principled evaluation of the effectiveness of selected aspects of the OECD's BEPS proposals to prevent "tax treaty abuse"