Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources?

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dc.contributor.advisorWest, Craigen_ZA
dc.contributor.authorStrandvik, Ulrik Bernharden_ZA
dc.date.accessioned2015-01-08T20:05:51Z
dc.date.available2015-01-08T20:05:51Z
dc.date.issued2011en_ZA
dc.descriptionIncludes bibliographical references (leaves 115-119).en_ZA
dc.description.abstractThis thesis tests the sufficiency of the definition of permanent establishments (PE), as contained in the Double Tax Agreements (DTAs) of selected "fishing rich" African countries, in protecting their taxing rights over profits made by non-residents from fishing in the waters of their states. The concept and meaning of "fixed place of residence" and "any other place of extraction” of natural resources is analysed in the context of establishing a PE in the Source State, taking various rules of interpretation, commentaries, judicial and academic views into account. It is concluded that although there are strong arguments in support of the view that a fishing vessel can be considered a fixed place of business, a prudent approach should be adopted. A fishing vessel is not a PE, unless specifically included in the specific DTA of Contracting States.en_ZA
dc.identifier.apacitationStrandvik, U. B. (2011). <i>Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources?</i>. (Thesis). University of Cape Town ,Faculty of Law ,Department of Commercial Law. Retrieved from http://hdl.handle.net/11427/11806en_ZA
dc.identifier.chicagocitationStrandvik, Ulrik Bernhard. <i>"Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources?."</i> Thesis., University of Cape Town ,Faculty of Law ,Department of Commercial Law, 2011. http://hdl.handle.net/11427/11806en_ZA
dc.identifier.citationStrandvik, U. 2011. Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources?. University of Cape Town.en_ZA
dc.identifier.ris TY - Thesis / Dissertation AU - Strandvik, Ulrik Bernhard AB - This thesis tests the sufficiency of the definition of permanent establishments (PE), as contained in the Double Tax Agreements (DTAs) of selected "fishing rich" African countries, in protecting their taxing rights over profits made by non-residents from fishing in the waters of their states. The concept and meaning of "fixed place of residence" and "any other place of extraction” of natural resources is analysed in the context of establishing a PE in the Source State, taking various rules of interpretation, commentaries, judicial and academic views into account. It is concluded that although there are strong arguments in support of the view that a fishing vessel can be considered a fixed place of business, a prudent approach should be adopted. A fishing vessel is not a PE, unless specifically included in the specific DTA of Contracting States. DA - 2011 DB - OpenUCT DP - University of Cape Town LK - https://open.uct.ac.za PB - University of Cape Town PY - 2011 T1 - Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources? TI - Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources? UR - http://hdl.handle.net/11427/11806 ER - en_ZA
dc.identifier.urihttp://hdl.handle.net/11427/11806
dc.identifier.vancouvercitationStrandvik UB. Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources?. [Thesis]. University of Cape Town ,Faculty of Law ,Department of Commercial Law, 2011 [cited yyyy month dd]. Available from: http://hdl.handle.net/11427/11806en_ZA
dc.language.isoengen_ZA
dc.publisher.departmentDepartment of Commercial Lawen_ZA
dc.publisher.facultyFaculty of Lawen_ZA
dc.publisher.institutionUniversity of Cape Town
dc.subject.otherTaxationen_ZA
dc.titleAfrica and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources?en_ZA
dc.typeMaster Thesis
dc.type.qualificationlevelMasters
dc.type.qualificationnameMComen_ZA
uct.type.filetypeText
uct.type.filetypeImage
uct.type.publicationResearchen_ZA
uct.type.resourceThesisen_ZA
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