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Author: Van Schalkwyk, L.

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A critical analysis of the concepts permanent establishment and foreign business establishment

Similar Items: A critical analysis of the concepts permanent establishment and foreign business establishment

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Die omvang van rente onderhewig aan, en die tydsberekening en koers van die heffing van terughoudingsbelasting op rente ingevolge artikel 50A-H van die Inkomstebelastingwet, no. 58 van 1962
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An analysis of sections 11D(1)(A) and 11D(5)(B) of the income tax Act No. 58 of 1962 as amended
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Critical analysis of the components of the transfer pricing provisions contained in Section 31(2) of the Income Tax Act, no 58 of 1962
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An analysis of Section 80A(C)(ii) of the Income Tax Act no. 58 of 1962 as amended
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The deductibility of future expenditure on contract in terms of section 24C
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Determining to what extent the “money-lender test” needs to be satisfied in the context of South African investment holding companies, focusing on the requirements of section 11(a) and 24J(2) of the Income Tax Act No. 58 of 1962
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Debt capitalisation: investigating the term ‘reduction amount’ in the Income Tax Act 58 of 1962
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Warranted and warrantless search and seizure in South African income tax law : the development, operation, constitutionality and remedies of a taxpayer
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An analysis of the interaction between section 7(8) and section 31(2) of the Income Tax Act No. 58 of 1962 when applied to non-interest-bearing loans from resident natural persons to connected non-resident trusts
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The treatment of section 24J instruments denominated in a foreign currency with regard to the categorisation as fixed or variable rate instruments and the interaction between section 24J, section 25D (foreign currency translation rules) and section 24I (gains and losses on foreign exchange transactions)
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A critical evaluation of section 15A of the Income Tax Act
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Abuse of legal personality to avoid tax : piercing the corporate veil as remedy in case of the abuse of legal personality for tax purposes
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Investigating whether the granting of services and the right of use of assets would constitute dividends in specie
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An analysis of the tax deductions in life right exchange agreements
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The imputability of ‘income on income’ under section 7(3) of the Income Tax Act
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The applicability of section 24I of the Income Tax Act No. 58 of 1962 to bitcoin gains and losses
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A critical analysis of Section 8C : taxation of directors and employees on vesting of equity instruments
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Assessing the normal tax implications of a home swap for a resident owning property in South Africa
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A critical analysis of the interpretation of the term "associated enterprise" in provisions in South African double taxation agreement based on Article 9 of the Organisation for Economic Cooperation and Development's Model Tax Convention on Income and on Capital
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Consistency as a desirable and achievable objective in the proposed rewrite of the South African Income Tax Act, 1962 (Act No. 58 of 1962)
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A critical analysis of the interpretation and application of the “income from trade” requirement contained in section 20(1) of the Income Tax Act, 58 of 1962 with regard to the carrying forward of the balance of assessed losses
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Value-added tax : a critical analysis of input tax in respect of share issue costs
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Aspects of the administrative law relationship between the taxpayer and the Commissioner for Inland Revenue
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A critical analysis of the scope of the foreign services reportable arrangement provision of the Tax Administration Act of South Africa