Browsing by Author "Beukes, Marvan"

Now showing 1 - 2 of 2
  • Thumbnail Image
    Item
    Open Access
    "Expenditure"
    (2014) Beukes, Marvan; Gutuza, Tracy
    This dissertation endeavours to analyse the case Commissioner for the South African Revenue Service v Labat Africa Ltd and its consequences in order to conclude whether the tax law created by the court is sound. Specifically it looks at the progression of the case through the different courts, as well as the other court cases referred to in the different courts. The research found that the case defined, for the first time, the term "expenditure" for South African Income Tax purposes. It also found that the new definition may have created consequences for the interpretation of other sections of the Income Tax Act.
  • Thumbnail Image
    Item
    Open Access
    Thin capitalisation in South Africa, including a critical analysis of the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions
    (2014) Beukes, Marvan; Gutuza, Tracy
    This dissertation endeavours to analyse the anti-avoidance measures implemented (and planned for the future) in South Africa to combat the practice known as "thin capitalisation". It critically analyses the Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions: Thin capitalisation. It concludes that the arms-length approach is not suitable for South Africa and that it is essential that a system of advance pricing agreements be implemented.