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An evaluation of how the new Headquarter Company tax provisions in South Africa should be amended to result in a direct benefit to the fiscus
Dissertation (MCom)--University of Pretoria, 2012.
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| Format: | Thesis |
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University of Pretoria
2013
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| _version_ | 1867613459472973824 |
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| access_status_str | Open Access |
| author2 | Manyaka, Puleng Owen |
| author_browse | Manyaka, Puleng Owen |
| author_facet | Manyaka, Puleng Owen |
| collection | Thesis |
| dc_rights_str_mv | © 2012 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria |
| description | Dissertation (MCom)--University of Pretoria, 2012. |
| format | Thesis |
| id | oai:repository.up.ac.za:2263/26404 |
| institution | University of Pretoria (South Africa) |
| last_indexed | 2026-06-10T12:36:29.146Z |
| license_str | Other — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UPSpace — University of Pretoria Institutional Repository |
| publishDate | 2013 |
| publishDateRange | 2013 |
| publishDateSort | 2013 |
| publisher | University of Pretoria |
| publisherStr | University of Pretoria |
| record_format | dspace |
| source_str | UPSpace — University of Pretoria Institutional Repository |
| spelling | oai:repository.up.ac.za:2263/26404 An evaluation of how the new Headquarter Company tax provisions in South Africa should be amended to result in a direct benefit to the fiscus Manyaka, Puleng Owen rbennett.pta@gmail.com Bennett, Rene Substance requirements Intermediary holding company (ihc) Headquarter company regime UCTD Dissertation (MCom)--University of Pretoria, 2012. During the past few years, South Africa established a competitive headquarter tax regime, which was implemented with the primary goal of encouraging foreign direct investment in South Africa. An important secondary goal was for South Africa to be used as a Holding Company location through which multinational entities can invest into sub-Saharan Africa. Although the Headquarter Company regime was developed to prevent any direct losses to the fiscus, it did not create any direct benefits or advantages. Internationally, substance requirements have a two-fold purpose: to encourage resident tax entities to engage in active economic activities, and to prohibit income losses due to tax avoidance or evasion. Some of the most important substance requirements are set out in a country’s policies on permanent establishment, beneficial ownership and transfer pricing. Another effective manner to encourage economic activity is to offer tax incentives to activities usually associated with Headquarter Companies. These activities include, but are not limited to active management, granting loans, leasing, and the provision of intellectual property. This research concludes that the inclusion of substance requirements in headquarter tax legislation will not only directly benefit the fiscus, but it will indirectly benefit the economy as a whole. Taxation unrestricted 2013-09-07T05:06:22Z 2013-07-30 2013-09-07T05:06:22Z 2013-04-18 2012 2013-07-18 Dissertation Bennett, R 2012, An evaluation of how the new Headquarter Company tax provisions in South Africa should be amended to result in a direct benefit to the fiscus, MCom dissertation, University of Pretoria, Pretoria, viewed yymmdd < http://hdl.handle.net/2263/26404 > F13/4/558/gm http://hdl.handle.net/2263/26404 http://upetd.up.ac.za/thesis/available/etd-07182013-122859/ © 2012 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria application/pdf University of Pretoria |
| spellingShingle | Substance requirements Intermediary holding company (ihc) Headquarter company regime UCTD An evaluation of how the new Headquarter Company tax provisions in South Africa should be amended to result in a direct benefit to the fiscus |
| title | An evaluation of how the new Headquarter Company tax provisions in South Africa should be amended to result in a direct benefit to the fiscus |
| title_full | An evaluation of how the new Headquarter Company tax provisions in South Africa should be amended to result in a direct benefit to the fiscus |
| title_fullStr | An evaluation of how the new Headquarter Company tax provisions in South Africa should be amended to result in a direct benefit to the fiscus |
| title_full_unstemmed | An evaluation of how the new Headquarter Company tax provisions in South Africa should be amended to result in a direct benefit to the fiscus |
| title_short | An evaluation of how the new Headquarter Company tax provisions in South Africa should be amended to result in a direct benefit to the fiscus |
| title_sort | evaluation of how the new headquarter company tax provisions in south africa should be amended to result in a direct benefit to the fiscus |
| topic | Substance requirements Intermediary holding company (ihc) Headquarter company regime UCTD |
| url | http://hdl.handle.net/2263/26404 http://upetd.up.ac.za/thesis/available/etd-07182013-122859/ |