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Are South Africa's section 23m interest limitation rules sufficiently targeted and effective in combatting base erosion and profit shifting through earnings stripping schemes by associated enterprises?
Earnings stripping is a simple structure whereby one affiliate company resident in a low or no tax jurisdiction advances an intra-group loan to another affiliate member company resident in a high tax jurisdiction so that the latter makes excessive deductible interest payments. The overall effect of...
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| Format: | Thesis |
| Language: | English |
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Department of Commercial Law
2023
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