Full Text Available
Note: Clicking the button above will open the full text document at the original institutional repository in a new window.
The application of the new thin capitalisation rules in South Africa
Dissertation (MCom)--University of Pretoria, 2014.
Saved in:
| Other Authors: | |
|---|---|
| Format: | Thesis |
| Language: | English |
| Published: |
University of Pretoria
2014
|
| Subjects: | |
| Tags: |
No Tags, Be the first to tag this record!
|
| _version_ | 1867613469107290112 |
|---|---|
| access_status_str | Open Access |
| author2 | Dos Santos, T (Tosca). |
| author_browse | Dos Santos, T (Tosca). |
| author_facet | Dos Santos, T (Tosca). |
| collection | Thesis |
| dc_rights_str_mv | © 2014 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, 2014. |
| format | Thesis |
| id | oai:repository.up.ac.za:2263/41195 |
| institution | University of Pretoria (South Africa) |
| language | English |
| last_indexed | 2026-06-10T12:36:38.421Z |
| license_str | Other — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UPSpace — University of Pretoria Institutional Repository |
| publishDate | 2014 |
| publishDateRange | 2014 |
| publishDateSort | 2014 |
| 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:2263/41195 The application of the new thin capitalisation rules in South Africa Dos Santos, T (Tosca). tmohokare@sars.gov.za Mohokare, T. (Thabiso) Thin capitalisation Transfer pricing International transactions Connected person Arm’s length Safe harbour UCTD Dissertation (MCom)--University of Pretoria, 2014. South Africa, together with similar countries world-wide, has taken active steps to counter the negative effects of the concept of “Base Erosion and Profit Shifting” by tightening its transfer pricing legislation. The South African 2010 Taxation Laws Amendment Act includes certain changes to bring the transfer pricing rules contained under section 31 of the Income Tax Act no 58 of 1962 up to date. These changes are aimed at bringing the South African transfer pricing legislation in line with the Organisation for Economic Cooperation and Development (OECD) guidelines. The new section 31 is aimed at shifting focus from the old transaction-based wording, to a more substance-focused approach. This implies, therefore, that safe harbours will no longer be the main determinant in establishing whether or not a company is thinly capitalised. The major concerns raised by taxpayers regarding this new approach relate to the uncertainties with regard to its practical application. Thus, the new amendments have brought about various challenges, including, the standardisation of procedures, reducing the cost of compliance, and developing broad databases that can assist with the determination of the arm's length price. This study aims to analyse the practical difficulties with which taxpayers could be faced in the application of this new legislation. The study uses the United Kingdom to assess the effectiveness of the new thin capitalisation rules since their thin capitalisation provisions also appear to have been brought in line with the OECD guidelines. Taxation unrestricted 2014-08-12T08:50:57Z 2014-08-12T08:50:57Z 2014-04-01 2014 Mini Dissertation Mohokare, T 2014, The application of the new thin capitalisation rules in South Africa, MCom dissertation, University of Pretoria, Pretoria, viewed yymmdd <http://hdl.handle.net/2263/41195> F14/4/403/lm http://hdl.handle.net/2263/41195 en © 2014 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 | Thin capitalisation Transfer pricing International transactions Connected person Arm’s length Safe harbour UCTD The application of the new thin capitalisation rules in South Africa |
| title | The application of the new thin capitalisation rules in South Africa |
| title_full | The application of the new thin capitalisation rules in South Africa |
| title_fullStr | The application of the new thin capitalisation rules in South Africa |
| title_full_unstemmed | The application of the new thin capitalisation rules in South Africa |
| title_short | The application of the new thin capitalisation rules in South Africa |
| title_sort | application of the new thin capitalisation rules in south africa |
| topic | Thin capitalisation Transfer pricing International transactions Connected person Arm’s length Safe harbour UCTD |
| url | http://hdl.handle.net/2263/41195 |