A proposed interpretation of the phrase "subject to tax" in section 23M(2)(i)(aa) of the Income Tax Act, No 58 of 1962, when read in context of South African Tax Treaties

Following the tax policy recommendation of the Organisation for Economic Co-operation and Development (‘OECD')/Group of Twenty (‘G20') member countries, under the OECD/G20 Base Erosion and Profit Shifting Project: Action 4 (‘BEPS Action 4'), the South African legislature recently enacted an internat...

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