The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law?

dc.contributor.advisorGutuza, Tracy
dc.contributor.authorMarais, Retha
dc.date.accessioned2026-03-19T11:07:56Z
dc.date.available2026-03-19T11:07:56Z
dc.date.issued2010
dc.date.updated2026-03-19T07:38:31Z
dc.description.abstractThe face of commerce has become progressively more globalised in the past decades, facilitated by among other factors, telecommunication improvements and the ease and speed of travel.1 An increasing number of South African companies are expanding their business internationally, and directly controlled foreign investment is increasing consistently.2 Whilst the economic activity generated by the global expansion of South African companies is positive, it creates a problem for the South African government, in that the flight of capital may erode the domestic tax base. To address this problem, South Africa replaced source-based taxation with residence-based taxation as of 1 January 2001, leading to the taxation of its residents' worldwide income.
dc.identifier.apacitationMarais, R. (2010). <i>The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law?</i>. (). University of Cape Town ,Faculty of Law ,Centre for Law and Society. Retrieved from http://hdl.handle.net/11427/43019en_ZA
dc.identifier.chicagocitationMarais, Retha. <i>"The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law?."</i> ., University of Cape Town ,Faculty of Law ,Centre for Law and Society, 2010. http://hdl.handle.net/11427/43019en_ZA
dc.identifier.citationMarais, R. 2010. The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law?. . University of Cape Town ,Faculty of Law ,Centre for Law and Society. http://hdl.handle.net/11427/43019en_ZA
dc.identifier.ris TY - Thesis / Dissertation AU - Marais, Retha AB - The face of commerce has become progressively more globalised in the past decades, facilitated by among other factors, telecommunication improvements and the ease and speed of travel.1 An increasing number of South African companies are expanding their business internationally, and directly controlled foreign investment is increasing consistently.2 Whilst the economic activity generated by the global expansion of South African companies is positive, it creates a problem for the South African government, in that the flight of capital may erode the domestic tax base. To address this problem, South Africa replaced source-based taxation with residence-based taxation as of 1 January 2001, leading to the taxation of its residents' worldwide income. DA - 2010 DB - OpenUCT DP - University of Cape Town KW - Tax KW - South Africa KW - International law LK - https://open.uct.ac.za PB - University of Cape Town PY - 2010 T1 - The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law? TI - The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law? UR - http://hdl.handle.net/11427/43019 ER - en_ZA
dc.identifier.urihttp://hdl.handle.net/11427/43019
dc.identifier.vancouvercitationMarais R. The taxation in South Africa of business profits of controlled foreign companies: in conflict with international law?. []. University of Cape Town ,Faculty of Law ,Centre for Law and Society, 2010 [cited yyyy month dd]. Available from: http://hdl.handle.net/11427/43019en_ZA
dc.language.isoen
dc.language.rfc3066eng
dc.publisher.departmentCentre for Law and Society
dc.publisher.facultyFaculty of Law
dc.publisher.institutionUniversity of Cape Town
dc.subjectTax
dc.subjectSouth Africa
dc.subjectInternational law
dc.titleThe taxation in South Africa of business profits of controlled foreign companies: in conflict with international law?
dc.typeThesis / Dissertation
dc.type.qualificationlevelMasters
dc.type.qualificationlevelLLM
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