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dc.contributor.advisorPotgieter, C.
dc.contributor.authorDe Abreu, Jeannine Nettoen_US
dc.date.accessioned2011-08-25T06:32:43Z
dc.date.available2011-08-25T06:32:43Z
dc.date.issued2010en_US
dc.identifier.urihttp://hdl.handle.net/10394/4476
dc.descriptionThesis (M.Com. (Tax))--North-West University, Potchefstroom Campus, 2011.
dc.description.abstractControlled foreign company ('CFC') legislation was introduced in phases to co-incide with South Africa's move from a source based system to a residence based system. Initially with the introduction of the legislation it was directed at those foreign entities earning passive income. However, over the years the legislation has been amended to include active income of entities and additional aspects to the section have been inserted to provide clarity for taxpayers. An increase in cross border transactions and offshore investment has necessitated the need to introduce CFC legislation into the revenue codes of many countries, South Africa being one of them. In most revenue codes where CFC or similar legislation has been introduced it is one of the most complex areas in a country's revenue code (Sandler, 1998:23). This mini-dissertation aims to interpret section 9D and also aims to provide guidance on its application in practice with the help of practical examples and reference to relevant international case law. The end result of this research is a proposed interpretation note on section 9D which is attached as Appendix 1.en_US
dc.publisherNorth-West University
dc.subjectSection 9D of the Income Tax Acten_US
dc.subjectControlled foreign companyen_US
dc.subjectCountry of residenceen_US
dc.subjectForeign business establishmenten_US
dc.subjectForeign companyen_US
dc.subjectForeign financial instrument holding companyen_US
dc.subjectForeign tax yearen_US
dc.subjectParticipation rightsen_US
dc.subjectVoting rightsen_US
dc.subjectPermanent establishmenten_US
dc.subjectComparable pricesen_US
dc.subjectPassive incomeen_US
dc.titleA suggested interpretation note for section 9D of the Income Tax Acten
dc.typeThesisen_US
dc.description.thesistypeMastersen_US


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