Similar Items: The History and Relevance of the Beneficial Ownership Concept in Tax Treaties ? Specifically in the context of the Introduction of the Principal Purpose Test
- The meaning of 'beneficial ownership' and the use thereof for tax treaty shopping and tax avoidance
- Does a mineral right constitute 'immovable property' for purposes of the Income Tax Act and double tax treaties?
- Seeking deviations from South Africaメs tax treaty policy with respect to treaties in Africa: evidence from the treaty practice
- An insight into the development of the royalty definition contained in modern model tax conventions and the evolution of the international tax meaning of 'beneficial ownership'
- Residence of an entity for tax purposes – South Africa: a review of the concept ‘place of effective management
- The legal status of tax treaties in South Africa
Author: Roeleveld, Jennifer
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