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.