Similar Items: South Africa's Restrictions on Interest Deductions and Their Compatibility with the Non-Discrimination Provisions of the 2017 Version of the OECD Model
- Is there a divergence between the OECD Transfer Pricing Guidelines and post-BEPS interpretation of the Arm?s Length Principle in OECD materials, with emphasis on the control of risk and value creation?
- A comparison of the substantive aspects of impermissible tax arrangements under South Africa's General Anti-Avoidance Rule and the Principal Purpose Test with specific reference to the examples found within the 2017 OECD Model Tax Convention
- 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
- A critical analysis of whether the current legislated exit tax provisions of South Africa are proportional to the legitimate purpose of those provisions
- The tax deductibility of contingent liabilities transferred in the sale of a going concern
- A principled evaluation of the effectiveness of selected aspects of the OECD's BEPS proposals to prevent "tax treaty abuse"
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"