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An international comparison - tax implication of a controlled foreign company ceased to be controlled in South Africa

Dissertation (MCom)--University of Pretoria, 2014.

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Other Authors: Du Preez, Hanneke
Format: Thesis
Language:English
Published: University of Pretoria 2014
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access_status_str Open Access
author2 Du Preez, Hanneke
author_browse Du Preez, Hanneke
author_facet Du Preez, Hanneke
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:2263/41248
institution University of Pretoria (South Africa)
language English
last_indexed 2026-06-10T12:37:23.306Z
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:2263/41248 An international comparison - tax implication of a controlled foreign company ceased to be controlled in South Africa Du Preez, Hanneke avermeulen@deloitte.co.za Vermeulen, Ansius M. Controlled foreign company Tax residents Exit tax charge Tax policies Disposal Equity shares UCTD Dissertation (MCom)--University of Pretoria, 2014. As a result of globalisation there are endless business opportunities out there in the business world. South African tax residents may purchase shares in a foreign company as an investment which can lead to that company being effectively controlled in South Africa for South African tax purposes. When a controlled foreign company ceases to be a controlled by South African tax residents it is deemed to have disposed of its assets the day immediately before this event and certain exit tax charges should considered. Sound tax policies are crucial to ensure stability in any tax system. Tax legislation may be amended from time to time in order to ensure this stability in the South African tax system. No research has been done on the practical implication of current amendments to legislation affecting a controlled foreign company when it ceases to be controlled in South Africa as a direct result of the issuing of new equity shares by the controlled foreign company to foreign investors. The aim of this study was to discuss the current amendments to tax legislation affecting controlled foreign companies as well as the practical issues experienced by controlled foreign companies and South African tax residents. Furthermore, the study aims to demonstrate whether South Africa’s tax legislation is in line with the international norm by comparing the literature reviewed, the results of case study and information gathered through interviews to the United Kingdom’s tax legislation. hb2014 Taxation unrestricted 2014-08-13T12:57:22Z 2014-08-13T12:57:22Z 2014-04-01 2014 Mini Dissertation Vermeulen, A 2014, An international comparison - tax implication of a controlled foreign company ceased to be controlled in South Africa, MCom dissertation, University of Pretoria, Pretoria, viewed yymmdd <http://hdl.handle.net/2263/41248> F14/4/442 http://hdl.handle.net/2263/41248 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 Controlled foreign company
Tax residents
Exit tax charge
Tax policies
Disposal
Equity shares
UCTD
An international comparison - tax implication of a controlled foreign company ceased to be controlled in South Africa
title An international comparison - tax implication of a controlled foreign company ceased to be controlled in South Africa
title_full An international comparison - tax implication of a controlled foreign company ceased to be controlled in South Africa
title_fullStr An international comparison - tax implication of a controlled foreign company ceased to be controlled in South Africa
title_full_unstemmed An international comparison - tax implication of a controlled foreign company ceased to be controlled in South Africa
title_short An international comparison - tax implication of a controlled foreign company ceased to be controlled in South Africa
title_sort international comparison tax implication of a controlled foreign company ceased to be controlled in south africa
topic Controlled foreign company
Tax residents
Exit tax charge
Tax policies
Disposal
Equity shares
UCTD
url http://hdl.handle.net/2263/41248