Does South Africa have a coherent policy for source-based taxation based on the permanent establishment concept, and how has this policy been implemented in its bilateral tax treaties?
| dc.contributor.advisor | Hattingh, Johann | |
| dc.contributor.author | Eksteen, Michiel Marthinus | |
| dc.date.accessioned | 2020-03-06T10:03:26Z | |
| dc.date.available | 2020-03-06T10:03:26Z | |
| dc.date.issued | 2019 | |
| dc.date.updated | 2020-03-05T07:17:20Z | |
| dc.description.abstract | The difference between South Africa’s domestic PE definition and the PE definition in its various DTCs and regional MTCs suggest some material inconsistency in South Africa’s PE policy. The research question this minor dissertation seeks to answer is whether South Africa has a coherent PE policy for source-based taxation. In addressing this question, this thesis considered what South Africa’s PE negotiating policy is and identified trends in its tax treaty practice in order to determine any inconsistency with its domestic PE definition. The key finding arising from the research of this minor dissertation is that South Africa does not have a coherent PE policy as its domestic policy is based on the OECD PE definition from time to time, whereas its tax treaty negotiating position and tax treaty practice is closely aligned with the 2006 SA MTC. Finally, this thesis provide recommendations to South Africa’s relevant fiscal authorities on how to reform the PE policy in a coherent manner. | |
| dc.identifier.apacitation | Eksteen, M. M. (2019). <i>Does South Africa have a coherent policy for source-based taxation based on the permanent establishment concept, and how has this policy been implemented in its bilateral tax treaties?</i>. (). ,Faculty of Law ,Department of Commercial Law. Retrieved from http://hdl.handle.net/11427/31502 | en_ZA |
| dc.identifier.chicagocitation | Eksteen, Michiel Marthinus. <i>"Does South Africa have a coherent policy for source-based taxation based on the permanent establishment concept, and how has this policy been implemented in its bilateral tax treaties?."</i> ., ,Faculty of Law ,Department of Commercial Law, 2019. http://hdl.handle.net/11427/31502 | en_ZA |
| dc.identifier.citation | Eksteen, M.M. 2019. Does South Africa have a coherent policy for source-based taxation based on the permanent establishment concept, and how has this policy been implemented in its bilateral tax treaties?. . ,Faculty of Law ,Department of Commercial Law. http://hdl.handle.net/11427/31502 | en_ZA |
| dc.identifier.ris | TY - Thesis / Dissertation AU - Eksteen, Michiel Marthinus AB - The difference between South Africa’s domestic PE definition and the PE definition in its various DTCs and regional MTCs suggest some material inconsistency in South Africa’s PE policy. The research question this minor dissertation seeks to answer is whether South Africa has a coherent PE policy for source-based taxation. In addressing this question, this thesis considered what South Africa’s PE negotiating policy is and identified trends in its tax treaty practice in order to determine any inconsistency with its domestic PE definition. The key finding arising from the research of this minor dissertation is that South Africa does not have a coherent PE policy as its domestic policy is based on the OECD PE definition from time to time, whereas its tax treaty negotiating position and tax treaty practice is closely aligned with the 2006 SA MTC. Finally, this thesis provide recommendations to South Africa’s relevant fiscal authorities on how to reform the PE policy in a coherent manner. DA - 2019 DB - OpenUCT DP - University of Cape Town KW - International Taxation LK - https://open.uct.ac.za PY - 2019 T1 - Does South Africa have a coherent policy for source-based taxation based on the permanent establishment concept, and how has this policy been implemented in its bilateral tax treaties? TI - Does South Africa have a coherent policy for source-based taxation based on the permanent establishment concept, and how has this policy been implemented in its bilateral tax treaties? UR - http://hdl.handle.net/11427/31502 ER - | en_ZA |
| dc.identifier.uri | http://hdl.handle.net/11427/31502 | |
| dc.identifier.vancouvercitation | Eksteen MM. Does South Africa have a coherent policy for source-based taxation based on the permanent establishment concept, and how has this policy been implemented in its bilateral tax treaties?. []. ,Faculty of Law ,Department of Commercial Law, 2019 [cited yyyy month dd]. Available from: http://hdl.handle.net/11427/31502 | en_ZA |
| dc.language.rfc3066 | eng | |
| dc.publisher.department | Department of Commercial Law | |
| dc.publisher.faculty | Faculty of Law | |
| dc.subject | International Taxation | |
| dc.title | Does South Africa have a coherent policy for source-based taxation based on the permanent establishment concept, and how has this policy been implemented in its bilateral tax treaties? | |
| dc.type | Master Thesis | |
| dc.type.qualificationlevel | Masters | |
| dc.type.qualificationname | LLM |