Similar Items: 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 principled evaluation of the effectiveness of selected aspects of the OECD's BEPS proposals to prevent "tax treaty abuse"
- Taxability of non-resident online retailers in South Africa and the OECD’s BEPS action plan
- The effect of the Coca-Cola transfer pricing cases and selected shifts in the international tax regime on the determination of an arm's length price
- South Africa's Restrictions on Interest Deductions and Their Compatibility with the Non-Discrimination Provisions of the 2017 Version of the OECD Model
- Effective management – the South African courts’ interpretation compared to OECD principles
- The OECD transfer pricing guidelines: an analysis of their application in the South Africa legal regime
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"