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A comparison of the taxation of foreign investors between South Africa and Mauritius

Dissertation (MCom (Taxation))--University of Pretoria, 2011.

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Other Authors: jaicee.bam@bcx.co.za
Format: Thesis
Language:English
Published: University of Pretoria 2013
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author2 jaicee.bam@bcx.co.za
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dc_rights_str_mv © 2011, 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 (Taxation))--University of Pretoria, 2011.
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institution University of Pretoria (South Africa)
language English
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license_str Other — see source repository
provenance_str_mv Harvested via OAI-PMH from UPSpace — University of Pretoria Institutional Repository
publishDate 2013
publishDateRange 2013
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spelling oai:repository.up.ac.za:2263/30697 A comparison of the taxation of foreign investors between South Africa and Mauritius jaicee.bam@bcx.co.za Prof M J Cronje Mr R Oosthuizen Bam, Jaicee UCTD Controlled foreign company Mauritius Foreign investors Permanent establishment International headquarter company Double tax agreement Dissertation (MCom (Taxation))--University of Pretoria, 2011. South Africa's ability to attract foreign investors and the related tax legislation and Exchange Controls surrounding it has been a topic of great debate over the past couple of years. There has been a constant flow of multinational companies to Mauritius to house their headquarters there to use it as a gateway into African countries. Although prior research has been performed in the United States on the taxation of foreign investors, no research on this topic has been performed from a South African perspective. This study extends on these prior studies by performing an analysis of the taxation of foreign investors and the related exchange controls from a South African perspective. The main aim of this study is to determine how South Africa can amend the current income tax legislation and exchange controls effectively to make South Africa more attractive for foreign investors and to be more competitive with Mauritius for multinationals to host their headquarters in South Africa as a gateway to other African countries. From a theoretical perspective, the study aims to identify areas in the South African tax legislation to be revisited and revised or refined to make South Africa more attractive for foreign investors and to make it more competitive to attract multinationals to South Africa. Although South Africa introduced the new international headquarter company regime in 2011, this study aims to investigate, analyse and compare it to the previous attempt in 2002 as well as to an ideal international headquarter company regime. This study compares South Africa to Mauritius as a tax jurisdiction in terms of effective tax rates, international headquarter company regimes as well as practicality with regard to its infrastructures, banking networks, tax treaty agreements, quality of life and various options available. This study also aims to provide suggestions for the National Treasury to amend current tax legislation to make South Africa more attractive for foreign investors and to make it more competitive with other tax jurisdictions, such as Mauritius. Copyright 2011, 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. Please cite as follows: Bam, J 2011, A comparison of the taxation of foreign investors between South Africa and Mauritius, MCom dissertation, University of Pretoria, Pretoria, viewed yymmdd < http://upetd.up.ac.za/thesis/available/etd-03222012-130046 / > F12/4/172/gm Taxation MCom (Taxation) restricted 2013-09-09T07:24:49Z 2012-06-04 2013-09-09T07:24:49Z 2012-04-16 2011-06-04 2012-03-22 Dissertation Bam, J 2011, A comparison of the taxation of foreign investors between South Africa and Mauritius, MCom dissertation, University of Pretoria, Pretoria, viewed yymmdd < http://upetd.up.ac.za/thesis/available/etd-03222012-130046/ > http://hdl.handle.net/2263/30697 http://upetd.up.ac.za/thesis/available/etd-03222012-130046/ en © 2011, 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 UCTD
Controlled foreign company
Mauritius
Foreign investors
Permanent establishment
International headquarter company
Double tax agreement
A comparison of the taxation of foreign investors between South Africa and Mauritius
title A comparison of the taxation of foreign investors between South Africa and Mauritius
title_full A comparison of the taxation of foreign investors between South Africa and Mauritius
title_fullStr A comparison of the taxation of foreign investors between South Africa and Mauritius
title_full_unstemmed A comparison of the taxation of foreign investors between South Africa and Mauritius
title_short A comparison of the taxation of foreign investors between South Africa and Mauritius
title_sort comparison of the taxation of foreign investors between south africa and mauritius
topic UCTD
Controlled foreign company
Mauritius
Foreign investors
Permanent establishment
International headquarter company
Double tax agreement
url http://hdl.handle.net/2263/30697
http://upetd.up.ac.za/thesis/available/etd-03222012-130046/