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Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions
This dissertation endeavours to analyse the anti-avoidance measures implemented (and planned for the future) in South Africa to combat the practice known as "thin capitalisation". It critically analyses the Draft Interpretation Note on the determination of the taxable income of certain persons from...
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| Format: | Thesis |
| Language: | English |
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Department of Finance and Tax
2016
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| _version_ | 1867613225339584513 |
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| access_status_str | Open Access |
| author | Beukes, Marvan |
| author2 | Gutuza, Tracy |
| author_browse | Beukes, Marvan Gutuza, Tracy |
| author_facet | Gutuza, Tracy Beukes, Marvan |
| author_sort | Beukes, Marvan |
| collection | Thesis |
| description | This dissertation endeavours to analyse the anti-avoidance measures implemented (and planned for the future) in South Africa to combat the practice known as "thin capitalisation". It critically analyses the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions: Thin capitalisation. It concludes that the arms-length approach is not suitable for South Africa and that it is essential that a system of advance pricing agreements be implemented. |
| format | Thesis |
| id | oai:open.uct.ac.za:11427/18623 |
| institution | University of Cape Town (South Africa) |
| language | eng |
| last_indexed | 2026-06-10T12:32:45.765Z |
| license_str | Not specified — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UCTD — University of Cape Town Open Access Repository |
| publishDate | 2016 |
| publishDateRange | 2016 |
| publishDateSort | 2016 |
| publisher | Department of Finance and Tax |
| publisherStr | Department of Finance and Tax |
| record_format | dspace |
| source_str | UCTD — University of Cape Town Open Access Repository |
| spelling | oai:open.uct.ac.za:11427/18623 Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions Beukes, Marvan Gutuza, Tracy Tax Law This dissertation endeavours to analyse the anti-avoidance measures implemented (and planned for the future) in South Africa to combat the practice known as "thin capitalisation". It critically analyses the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions: Thin capitalisation. It concludes that the arms-length approach is not suitable for South Africa and that it is essential that a system of advance pricing agreements be implemented. 2016-04-05T11:48:55Z 2016-04-05T11:48:55Z 2014 Master Thesis Masters MPhil http://hdl.handle.net/11427/18623 eng application/pdf Department of Finance and Tax Faculty of Commerce University of Cape Town |
| spellingShingle | Tax Law Beukes, Marvan Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions |
| thesis_degree_str | Master's |
| title | Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions |
| title_full | Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions |
| title_fullStr | Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions |
| title_full_unstemmed | Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions |
| title_short | Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions |
| title_sort | thin capitalisation in south africa including a critical analysis of the draft interpretation note on the determination of the taxable income of certain persons from international transactions |
| topic | Tax Law |
| url | http://hdl.handle.net/11427/18623 |
| work_keys_str_mv | AT beukesmarvan thincapitalisationinsouthafricaincludingacriticalanalysisofthedraftinterpretationnoteonthedeterminationofthetaxableincomeofcertainpersonsfrominternationaltransactions |