The principles of source and residence taxation of electronic commerce transactions in South Africa
Abstract
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 focus will be on these principles as they manifest in the form of electronic commerce transactions on the Internet, a visible form of the global electronic revolution. Such examination will be undertaken in this study in order to determine what the most appropriate method would be for the South African Revenue Service to levy income tax for electronic commerce transactions, namely, source-based or residence-based income taxation.
Collections
- Law [834]
Related items
Showing items related by title, author, creator and subject.
-
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 ... -
The taxation of company distributions in respect of hybrid instruments in South Africa : lessons from Australia and Canada
(PER/PELJ, 2021)Tax legislation traditionally distinguishes between returns on investment paid on equity and debt instruments. In the main, returns on debt instruments (interest payments) are deductible for the paying company, while ... -
The incorporation of double taxation agreements into South African domestic law
(2015)There are different opinions as to the process whereby double taxation agreements (DTAs) are incorporated into South African law. This contribution aims to discuss some of the existing opinions and to offer a further ...
