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"Place of effective management" - a South Africa perspective
Dissertation (LLM)--University of Pretoria, 2013.
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| Format: | Thesis |
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University of Pretoria
2013
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| _version_ | 1867613663388499969 |
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| access_status_str | Open Access |
| author2 | Louw, C (Adv.) |
| author_browse | Louw, C (Adv.) |
| author_facet | Louw, C (Adv.) |
| 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 (LLM)--University of Pretoria, 2013. |
| format | Thesis |
| id | oai:repository.up.ac.za:2263/26663 |
| institution | University of Pretoria (South Africa) |
| last_indexed | 2026-06-10T12:39:43.676Z |
| 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:2263/26663 "Place of effective management" - a South Africa perspective Louw, C (Adv.) upetd@up.ac.za Jonker, Janien South African Revenue Service (SARS) South African Institute of Chartered Accountants (SAICA) Place of effective management (poem) UCTD Dissertation (LLM)--University of Pretoria, 2013. The comments submitted by The South African Institute of Chartered Accountants (hereinafter referred to as “SAICA”) to the Discussion Paper issued by the South African Revenue Service (hereinafter referred to as “SARS”) in respect of Interpretation Note 61, included the following important introductory comments: “We heartily welcome and endorse the revised approach, which brings the South African interpretation closer to international norm. South Africa is too small an economy in the world to be out of step with the general consensus view, including the views of our main treaty partners (who are mainly OECD members). It also reduces the prospect of having to resort to a mutual agreement procedure; not to mention reducing the likelihood of litigation in the South African courts.” South Africa‟s approach to the determination of a legal person‟s “place of effective management” (hereinafter referred to as “POEM”) differs from the international approach and has resulted not only in adverse tax implications, but also in a lot of uncertainty for various taxpayers. Mercantile Law unrestricted 2013-09-07T07:08:25Z 2013-07-29 2013-09-07T07:08:25Z 2013-04-18 2013-07-29 2013-07-25 Dissertation Jonker, J 2012, "Place of effective management" - a South Africa perspective , LLM dissertation, University of Pretoria, Pretoria, viewed yymmdd < http://hdl.handle.net/2263/26663 > F13/4/616/gm http://hdl.handle.net/2263/26663 http://upetd.up.ac.za/thesis/available/etd-07252013-120735/ © 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 | South African Revenue Service (SARS) South African Institute of Chartered Accountants (SAICA) Place of effective management (poem) UCTD "Place of effective management" - a South Africa perspective |
| title | "Place of effective management" - a South Africa perspective |
| title_full | "Place of effective management" - a South Africa perspective |
| title_fullStr | "Place of effective management" - a South Africa perspective |
| title_full_unstemmed | "Place of effective management" - a South Africa perspective |
| title_short | "Place of effective management" - a South Africa perspective |
| title_sort | place of effective management a south africa perspective |
| topic | South African Revenue Service (SARS) South African Institute of Chartered Accountants (SAICA) Place of effective management (poem) UCTD |
| url | http://hdl.handle.net/2263/26663 http://upetd.up.ac.za/thesis/available/etd-07252013-120735/ |