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Ensuring Favourable Taxing Rights for Business Profits : An Appraisal of the Permanent Establishment Concept in the UN and OECD Model Tax Conventions
Mini Dissertation (MCom)--University of Pretoria, 2019.
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| Format: | Thesis |
| Language: | English |
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University of Pretoria
2020
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| _version_ | 1867613641522544640 |
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| access_status_str | Open Access |
| author2 | Oguttu, Annet Wanyana |
| author_browse | Oguttu, Annet Wanyana |
| author_facet | Oguttu, Annet Wanyana |
| collection | Thesis |
| dc_rights_str_mv | © 2019 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 (MCom)--University of Pretoria, 2019. |
| format | Thesis |
| id | oai:repository.up.ac.za:2263/74960 |
| institution | University of Pretoria (South Africa) |
| language | English |
| last_indexed | 2026-06-10T12:39:22.809Z |
| license_str | Other — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UPSpace — University of Pretoria Institutional Repository |
| publishDate | 2020 |
| publishDateRange | 2020 |
| publishDateSort | 2020 |
| 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:2263/74960 Ensuring Favourable Taxing Rights for Business Profits : An Appraisal of the Permanent Establishment Concept in the UN and OECD Model Tax Conventions Oguttu, Annet Wanyana kenneth.collett@up.ac.za Franzsen, R.C.D. (Riel) Collett, Kenneth Andrew UCTD Mini Dissertation (MCom)--University of Pretoria, 2019. As taxation across borders have become a significant event, this study therefore focusses on the taxation of business profits within the context of cross border transactions, especially with reference to permanent establishments. The study places emphasise on the various requirements and variations of the permanent establishment concept as used and defined in the OECD and UN Model Tax Convention respectively, by drawing comparisons between the various requirements and also identifying variances. The study concluded by suggesting that the UN Model Double Tax Conventions offers better taxation of business profits from the perspective of developing countries, within the context of taxing business profits through the use of permanent establishments. Taxation MCom (Taxation) Unrestricted 2020-06-11T08:43:49Z 2020-06-11T08:43:49Z 2020 2019 Mini Dissertation Collett, KA 2019, Ensuring Favourable Taxing Rights for Business Profits : An Appraisal of the Permanent Establishment Concept in the UN and OECD Model Tax Conventions, MCom (Taxation) Mini Dissertation, University of Pretoria, Pretoria, viewed yymmdd <http://hdl.handle.net/2263/74960> A2020 http://hdl.handle.net/2263/74960 en © 2019 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 Ensuring Favourable Taxing Rights for Business Profits : An Appraisal of the Permanent Establishment Concept in the UN and OECD Model Tax Conventions |
| title | Ensuring Favourable Taxing Rights for Business Profits : An Appraisal of the Permanent Establishment Concept in the UN and OECD Model Tax Conventions |
| title_full | Ensuring Favourable Taxing Rights for Business Profits : An Appraisal of the Permanent Establishment Concept in the UN and OECD Model Tax Conventions |
| title_fullStr | Ensuring Favourable Taxing Rights for Business Profits : An Appraisal of the Permanent Establishment Concept in the UN and OECD Model Tax Conventions |
| title_full_unstemmed | Ensuring Favourable Taxing Rights for Business Profits : An Appraisal of the Permanent Establishment Concept in the UN and OECD Model Tax Conventions |
| title_short | Ensuring Favourable Taxing Rights for Business Profits : An Appraisal of the Permanent Establishment Concept in the UN and OECD Model Tax Conventions |
| title_sort | ensuring favourable taxing rights for business profits an appraisal of the permanent establishment concept in the un and oecd model tax conventions |
| topic | UCTD |
| url | http://hdl.handle.net/2263/74960 |