Similar Items: Characterisation for treaty purposes of manufactured dividends received in terms of securities lending arrangements
- 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
- 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
- The legal status of memoranda of understanding in relation to treaties for the avoidance of double taxation and information exchange
- Judicial review of revenue authority decisions in a specific tax treaty context – a study of the extent of convergence in the reasoning of different courts reviewing revenue authority decisions under model-based tax treaties
- A critical evaluation of the 1964 preferencial agreement (Labour agreement) for Mozambique mineworkers in the light of the South Africa - Mozambique DTC and the SADC treaty
- 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
Author: West, Craig
- Global convergence of tax judgments and principles between South African courts and foreign courts: Assessing evidence of convergence in South African case law and its desirability in a South African context
- The suitability and practicality of the OECD transfer pricing methods to Zimbabwe
- Is the definition of "permanent establishment", as used in the double tax agreements of selected 'oil rich' central and North African countries, sufficient to protect the taxing rights on the natural resources of these countries?
- Does the tax administration act sufficiently protect the taxpayers' right to privacy or provide the taxpayer with a right to be informed?
- Have the OECD Transfer Pricing Guidelines influenced the development of domestic legislation for transfer pricing and the outcome of court decisions in selected African states?
- The concept of social enterprise: an analysis of the current tax environment and proposed enabling tax incentives to aid the social enterprise