Browsing by Subject "Profit shifting"
Now showing items 1-7 of 7
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An analysis of Section 23M in light of the OECD best practice approach to interest limitation
(North-West University (South Africa) , Potchefstroom Campus, 2016)The ability of multinational companies to reduce their tax burden on their worldwide profits has generated public interest in recent years. Excessive interest deductions can be used to shift profits from one country to ... -
An analysis of Section 23M in light of the OECD guidelines relating to thin capitalisation
(2015)Base erosion in the form of profit shifting has become an increasing concern internationally as well as in South Africa. A significant type of base erosion in South Africa is in the form of excessive interest deductions ... -
A critical analysis of public disclosure of OECD country-by-country reporting
(North-West University (South Africa), 2021)Base Erosion and Profit Shifting (BEPS), tax transparency and public disclosure of company information have been contentious topics for world organisations and tax administrators globally for some time now. The discussions ... -
An evaluation of the South African controlled foreign company rules within the digital economy
(North-West University (South Africa), 2021)South Africa has controlled foreign companies (CFC) rules aimed at combating South African residents from shifting their taxable income outside the South African tax net by investing or transacting through South ... -
The relationship between transfer pricing adjustments and withholding tax on interest in South Africa
(North-West University (South Africa), 2020)In response to base erosion and profit shifting activities, section 31 of the Act was enacted to prevent profit shifting and base erosion brought about by the manipulation of cross-border transfer pricing practices carried ... -
Thin capitalisation : an analysis of the application of the amended section 31(3) of the Income Tax Act no. 58 of 1962
(North-West University (South Africa), Vaal Triangle Campus, 2015)The current Income Tax legislation, in relation to thin capitalisation, requires South African-based entities to transact at an arm’s length basis. This is in accordance with the Draft Interpretation Note issued by the ... -
Withholding tax on service fees as a method to combat base erosion and profit shifting
(North-West University (South Africa) , Potchefstroom Campus, 2015)Around the globe, including in South Africa, there has been an increasing occurrence of cross-border service fees being used by multinational enterprises to shift profits. South Africa did not have legislation to implement ...