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An analysis on the creation of a fixed place and agency permanent establishment and how BEPS action 7 will change the threshold.
Mini Dissertation (LLM)--University of Pretoria, 2017.
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| Format: | Thesis |
| Language: | English |
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University of Pretoria
2018
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| _version_ | 1867613654072950784 |
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| access_status_str | Open Access |
| author2 | Makola, Charles S. |
| author_browse | Makola, Charles S. |
| author_facet | Makola, Charles S. |
| collection | Thesis |
| dc_rights_str_mv | © 2018 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 | Mini Dissertation (LLM)--University of Pretoria, 2017. |
| format | Thesis |
| id | oai:repository.up.ac.za:2263/65635 |
| institution | University of Pretoria (South Africa) |
| language | English |
| last_indexed | 2026-06-10T12:39:34.803Z |
| license_str | Other — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UPSpace — University of Pretoria Institutional Repository |
| publishDate | 2018 |
| publishDateRange | 2018 |
| publishDateSort | 2018 |
| 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:2263/65635 An analysis on the creation of a fixed place and agency permanent establishment and how BEPS action 7 will change the threshold. Makola, Charles S. jolani.visser27@gmail.com Visser, Jolani UCTD Mini Dissertation (LLM)--University of Pretoria, 2017. This research study considers how BEPS Action 7 will change the creation of a fixed place PE and agency PE. The purpose of the study is to explore the current requirements of creating a fixed place PE and an agency PE and how BEPS Action 7 will change these requirements. The importance of the PE concept was identified as it provides the global parameter to determine a right of a country to impose tax on a non-resident. The PE concept creates the necessary connection between where the country and the non-residennt. Certain international practical concepts were discussed to ensure an appreciation for the complex world in which PEs operate. The research study then moves to the discussion of the requirements to create a fixed PE or an agency PE. The requirements of both require a sufficient nexus before a source country may tax the profit of the non-resident. As mentioned above, the purpose of this study is to explore how the proposed changes in BEPS Action 7 will change the current threshold of creating a fixed PE and agency PE. The development up until the final BEPS Action Package are discussed together with the MLI and how it is created to quickly and effectively change the current double tax agreements in force. The relationship between South Africa and BEPS and its elections specifically relating to PEs are also discussed. This research study concludes with recommendations by the Davis Tax Committee as well as the researcher’s own recommendation on South Africa’s election on the relevant articles in the MLI. Mercantile Law LLM Unrestricted 2018-07-16T07:56:01Z 2018-07-16T07:56:01Z 2018/04/17 2017 Mini Dissertation Visser, J 2017, An analysis on the creation of a fixed place and agency permanent establishment and how BEPS action 7 will change the threshold., LLM Mini Dissertation, University of Pretoria, Pretoria, viewed yymmdd <http://hdl.handle.net/2263/65635> A2018 http://hdl.handle.net/2263/65635 en © 2018 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 An analysis on the creation of a fixed place and agency permanent establishment and how BEPS action 7 will change the threshold. |
| title | An analysis on the creation of a fixed place and agency permanent establishment and how BEPS action 7 will change the threshold. |
| title_full | An analysis on the creation of a fixed place and agency permanent establishment and how BEPS action 7 will change the threshold. |
| title_fullStr | An analysis on the creation of a fixed place and agency permanent establishment and how BEPS action 7 will change the threshold. |
| title_full_unstemmed | An analysis on the creation of a fixed place and agency permanent establishment and how BEPS action 7 will change the threshold. |
| title_short | An analysis on the creation of a fixed place and agency permanent establishment and how BEPS action 7 will change the threshold. |
| title_sort | analysis on the creation of a fixed place and agency permanent establishment and how beps action 7 will change the threshold |
| topic | UCTD |
| url | http://hdl.handle.net/2263/65635 |