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The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law?
The face of commerce has become progressively more globalised in the past decades, facilitated by among other factors, telecommunication improvements and the ease and speed of travel.1 An increasing number of South African companies are expanding their business internationally, and directly controll...
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| Format: | Thesis |
| Language: | English English |
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Centre for Law and Society
2026
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| _version_ | 1867613162840260608 |
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| access_status_str | Open Access |
| author | Marais, Retha |
| author2 | Gutuza, Tracy |
| author_browse | Gutuza, Tracy Marais, Retha |
| author_facet | Gutuza, Tracy Marais, Retha |
| author_sort | Marais, Retha |
| collection | Thesis |
| description | The face of commerce has become progressively more globalised in the past decades, facilitated by among other factors, telecommunication improvements and the ease and speed of travel.1 An increasing number of South African companies are expanding their business internationally, and directly controlled foreign investment is increasing consistently.2 Whilst the economic activity generated by the global expansion of South African companies is positive, it creates a problem for the South African government, in that the flight of capital may erode the domestic tax base. To address this problem, South Africa replaced source-based taxation with residence-based taxation as of 1 January 2001, leading to the taxation of its residents' worldwide income. |
| format | Thesis |
| id | oai:open.uct.ac.za:11427/43019 |
| institution | University of Cape Town (South Africa) |
| language | English eng |
| last_indexed | 2026-06-10T12:31:45.395Z |
| license_str | Not specified — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UCTD — University of Cape Town Open Access Repository |
| publishDate | 2026 |
| publishDateRange | 2026 |
| publishDateSort | 2026 |
| publisher | Centre for Law and Society |
| publisherStr | Centre for Law and Society |
| record_format | dspace |
| source_str | UCTD — University of Cape Town Open Access Repository |
| spelling | oai:open.uct.ac.za:11427/43019 The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law? Marais, Retha Gutuza, Tracy Tax South Africa International law The face of commerce has become progressively more globalised in the past decades, facilitated by among other factors, telecommunication improvements and the ease and speed of travel.1 An increasing number of South African companies are expanding their business internationally, and directly controlled foreign investment is increasing consistently.2 Whilst the economic activity generated by the global expansion of South African companies is positive, it creates a problem for the South African government, in that the flight of capital may erode the domestic tax base. To address this problem, South Africa replaced source-based taxation with residence-based taxation as of 1 January 2001, leading to the taxation of its residents' worldwide income. 2026-03-19T11:07:56Z 2026-03-19T11:07:56Z 2010 2026-03-19T07:38:31Z Thesis / Dissertation Masters LLM http://hdl.handle.net/11427/43019 en eng application/pdf Centre for Law and Society Faculty of Law University of Cape Town |
| spellingShingle | Tax South Africa International law Marais, Retha The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law? |
| thesis_degree_str | Master's |
| title | The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law? |
| title_full | The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law? |
| title_fullStr | The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law? |
| title_full_unstemmed | The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law? |
| title_short | The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law? |
| title_sort | taxation in south africa of business profits of controlled foreign companies in conflict with international law |
| topic | Tax South Africa International law |
| url | http://hdl.handle.net/11427/43019 |
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