Does the proposed dividends tax overcome the international tax flaws that secondary tax on companies may have, namely exclusion from the scope of some double tax agreements and violation of the anti-discrimination provisions embodied in the OECD mode

 

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dc.contributor.advisor West, Craig en_ZA
dc.contributor.author Lovely, Graham en_ZA
dc.date.accessioned 2015-01-03T05:42:38Z
dc.date.available 2015-01-03T05:42:38Z
dc.date.issued 2011 en_ZA
dc.identifier.citation Lovely, G. 2011. Does the proposed dividends tax overcome the international tax flaws that secondary tax on companies may have, namely exclusion from the scope of some double tax agreements and violation of the anti-discrimination provisions embodied in the OECD mode. University of Cape Town. en_ZA
dc.identifier.uri http://hdl.handle.net/11427/11135
dc.description Includes bibliographical references (leaves 54-55). en_ZA
dc.description.abstract Secondary tax on companies (STC) and the new dividends tax and its exemptions therefrom could be in contravention of the non-discrimination provisions of Article 24(5) of the OECD MTC. This question has not been decided in a South African court. This dissertation proposes the resolution to this question. The outcome of this research may be particularly relevant in the context of the proposed new dividends tax and value extraction tax (“VET”) and the exemptions therefrom, which are, again, based on residency. en_ZA
dc.language.iso eng en_ZA
dc.subject.other Taxation en_ZA
dc.title Does the proposed dividends tax overcome the international tax flaws that secondary tax on companies may have, namely exclusion from the scope of some double tax agreements and violation of the anti-discrimination provisions embodied in the OECD mode en_ZA
dc.type Thesis / Dissertation en_ZA
uct.type.publication Research en_ZA
uct.type.resource Thesis en_ZA
dc.publisher.institution University of Cape Town
dc.publisher.faculty Faculty of Law en_ZA
dc.publisher.department Department of Commercial Law en_ZA
dc.type.qualificationlevel Masters en_ZA
dc.type.qualificationname MCom en_ZA
uct.type.filetype Text
uct.type.filetype Image


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