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An analysis of the possible fiscal consequences of a controlled foreign company being declared resident in South Africa– may SARS have its cake and eat it?

The issue considered in this paper proceeds from the basis of a hypothetical income tax assessment issued by SARS against a hypothetical taxpayer. The circumstances under which the hypothetical assessment is raised are as follows: suppose that Company A, a South African resident, owns 100% of the pa...

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Bibliographic Details
Main Author: Kotze, Salmon Ruan
Other Authors: Gutuza, Tracy
Format: Thesis
Language:English
Published: Department of Commercial Law 2020
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