Browsing by Subject "Place of effective management"
Now showing items 1-5 of 5
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Double taxation treaty interpretation : lessons from a case down under
(PER/PELJ, 2020)In the Australian case of Bywater Investments Ltd v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation (the Bywater case) the Australian High Court dealt with the question of whether certain ... -
The effectiveness of the 'place of effective management' tie-breaker rule in the OECD Model Tax Convention
(North-West University, 2010)Double taxation could arise in a situation where resident- resident conflicts occur. Resident–resident conflicts occur in the situation where both countries regard such a person as a “resident” for tax purposes under their ... -
An international comparative study of South African controlled foreign company legislation
(2014)Globalisation of trade and investment has led multinational enterprises to develop strategies to maximise profits by investing in countries with a favourable tax climate, resulting in loss of tax revenue to domestic ... -
The principles of source and residence taxation of electronic commerce transactions in South Africa
(North-West University, 2007)This study will present the traditional legal aspects for fiscal jurisdiction of direct taxation being the principles of source and residence income taxation as they have developed internationally and in South Africa. The ... -
The residence definition within the framework of the headquarter company regime in the context of investment into Africa
(2014)Since the declaration of South Africa as the Gateway to Africa in 2010 by National Treasury, various changes have been made to South African legislation to make South Africa more attractive to foreign investors looking to ...