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The possibility of base erosion and profit shifting through special economic zones: A critique of the South African and Kenyan SEZ regimes based on BEPS action 5

The OECD/G20's Base Erosion and Profit Shifting (BEPS) Project has been described as the most significant international tax initiative post the 2008/2009 global economic crisis. BEPS speaks to companies engaging in aggressive tax planning strategies that exploit loopholes in tax systems to make prof...

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Main Author: Chimbombi, Ame Rebecca
Other Authors: Hattingh, Johann
Format: Thesis
Language:English
Published: Department of Finance and Tax 2017
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access_status_str Open Access
author Chimbombi, Ame Rebecca
author2 Hattingh, Johann
author_browse Chimbombi, Ame Rebecca
Hattingh, Johann
author_facet Hattingh, Johann
Chimbombi, Ame Rebecca
author_sort Chimbombi, Ame Rebecca
collection Thesis
description The OECD/G20's Base Erosion and Profit Shifting (BEPS) Project has been described as the most significant international tax initiative post the 2008/2009 global economic crisis. BEPS speaks to companies engaging in aggressive tax planning strategies that exploit loopholes in tax systems to make profits 'disappear' or shift them to tax jurisdictions with little or no overall corporate tax. The BEPS Project has fifteen Actions targeting various formations, computations and permutations that could potentially give rise to BEPS. BEPS Action 5 is entitled "Countering Harmful Tax Practices More Effectively Taking into Account Transparency and Substance" and is of central importance to this minor dissertation. Special Economic Zones (SEZs) are a creature of international trade law that refers to spatially delimited areas within an economy afforded favourable administrative, regulatory and fiscal benefits when compared to the rest of the economy. The term SEZ is used as an 'umbrella' or 'label' encompassing various types of spatially delimited areas with favourable conditions. Examples of SEZs are Free Trade Zones (FTZs) and Export Processing Zones (EPZs). Although this minor-dissertation focuses mainly on tax benefits associated with SEZs, SEZs usually encompasses a wider range of benefits to the companies they host. Such other benefits could include a one-stop shop for setting up and processing work permits. This minor-dissertation examines whether South Africa and Kenya's SEZs create conducive environments for harmful tax practices in light of and as described in BEPS Action 5.
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institution University of Cape Town (South Africa)
language eng
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license_str Not specified — see source repository
provenance_str_mv Harvested via OAI-PMH from UCTD — University of Cape Town Open Access Repository
publishDate 2017
publishDateRange 2017
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publisher Department of Finance and Tax
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spelling oai:open.uct.ac.za:11427/23787 The possibility of base erosion and profit shifting through special economic zones: A critique of the South African and Kenyan SEZ regimes based on BEPS action 5 Chimbombi, Ame Rebecca Hattingh, Johann West, Craig International Taxation The OECD/G20's Base Erosion and Profit Shifting (BEPS) Project has been described as the most significant international tax initiative post the 2008/2009 global economic crisis. BEPS speaks to companies engaging in aggressive tax planning strategies that exploit loopholes in tax systems to make profits 'disappear' or shift them to tax jurisdictions with little or no overall corporate tax. The BEPS Project has fifteen Actions targeting various formations, computations and permutations that could potentially give rise to BEPS. BEPS Action 5 is entitled "Countering Harmful Tax Practices More Effectively Taking into Account Transparency and Substance" and is of central importance to this minor dissertation. Special Economic Zones (SEZs) are a creature of international trade law that refers to spatially delimited areas within an economy afforded favourable administrative, regulatory and fiscal benefits when compared to the rest of the economy. The term SEZ is used as an 'umbrella' or 'label' encompassing various types of spatially delimited areas with favourable conditions. Examples of SEZs are Free Trade Zones (FTZs) and Export Processing Zones (EPZs). Although this minor-dissertation focuses mainly on tax benefits associated with SEZs, SEZs usually encompasses a wider range of benefits to the companies they host. Such other benefits could include a one-stop shop for setting up and processing work permits. This minor-dissertation examines whether South Africa and Kenya's SEZs create conducive environments for harmful tax practices in light of and as described in BEPS Action 5. 2017-01-31T09:19:28Z 2017-01-31T09:19:28Z 2016 Master Thesis Masters MCom http://hdl.handle.net/11427/23787 eng application/pdf Department of Finance and Tax Faculty of Commerce University of Cape Town
spellingShingle International Taxation
Chimbombi, Ame Rebecca
The possibility of base erosion and profit shifting through special economic zones: A critique of the South African and Kenyan SEZ regimes based on BEPS action 5
thesis_degree_str Master's
title The possibility of base erosion and profit shifting through special economic zones: A critique of the South African and Kenyan SEZ regimes based on BEPS action 5
title_full The possibility of base erosion and profit shifting through special economic zones: A critique of the South African and Kenyan SEZ regimes based on BEPS action 5
title_fullStr The possibility of base erosion and profit shifting through special economic zones: A critique of the South African and Kenyan SEZ regimes based on BEPS action 5
title_full_unstemmed The possibility of base erosion and profit shifting through special economic zones: A critique of the South African and Kenyan SEZ regimes based on BEPS action 5
title_short The possibility of base erosion and profit shifting through special economic zones: A critique of the South African and Kenyan SEZ regimes based on BEPS action 5
title_sort possibility of base erosion and profit shifting through special economic zones a critique of the south african and kenyan sez regimes based on beps action 5
topic International Taxation
url http://hdl.handle.net/11427/23787
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