Establishing the residency of artificial persons in cross border transactions

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dc.contributor.authorTanyanyiwan, Vimbaien_ZA
dc.date.accessioned2014-11-14T19:48:08Z
dc.date.available2014-11-14T19:48:08Z
dc.date.issued2014en_ZA
dc.descriptionIncludes bibliographical references.en_ZA
dc.description.abstractThe basis of residence taxation is that residents enjoy protection in the state where they contribute towards the costs of government. In tax treaties residence is used for purposes of allocating income and taxing rights between contracting states. For treaty purposes residence is determined on a day to day basis, hence a person can be resident in two countries at concurrent time periods. It is important to determine the residence of a corporation in a specific jurisdiction for purposes of ascertaining the treaty benefits that the entity can enjoy and the allocation of income between contracting states in a treaty. Usually a company’s tax residence is considered to create a sufficient connection with the country that has jurisdiction over it. The recognition of the residence status of natural and juristic persons is the cornerstone of international taxation. Residence is also used as an antiavoidance tax measure in international tax.en_ZA
dc.identifier.apacitationTanyanyiwan, V. (2014). <i>Establishing the residency of artificial persons in cross border transactions</i>. (Thesis). University of Cape Town ,Faculty of Law ,Department of Commercial Law. Retrieved from http://hdl.handle.net/11427/9614en_ZA
dc.identifier.chicagocitationTanyanyiwan, Vimbai. <i>"Establishing the residency of artificial persons in cross border transactions."</i> Thesis., University of Cape Town ,Faculty of Law ,Department of Commercial Law, 2014. http://hdl.handle.net/11427/9614en_ZA
dc.identifier.citationTanyanyiwan, V. 2014. Establishing the residency of artificial persons in cross border transactions. University of Cape Town.en_ZA
dc.identifier.ris TY - Thesis / Dissertation AU - Tanyanyiwan, Vimbai AB - The basis of residence taxation is that residents enjoy protection in the state where they contribute towards the costs of government. In tax treaties residence is used for purposes of allocating income and taxing rights between contracting states. For treaty purposes residence is determined on a day to day basis, hence a person can be resident in two countries at concurrent time periods. It is important to determine the residence of a corporation in a specific jurisdiction for purposes of ascertaining the treaty benefits that the entity can enjoy and the allocation of income between contracting states in a treaty. Usually a company’s tax residence is considered to create a sufficient connection with the country that has jurisdiction over it. The recognition of the residence status of natural and juristic persons is the cornerstone of international taxation. Residence is also used as an antiavoidance tax measure in international tax. DA - 2014 DB - OpenUCT DP - University of Cape Town LK - https://open.uct.ac.za PB - University of Cape Town PY - 2014 T1 - Establishing the residency of artificial persons in cross border transactions TI - Establishing the residency of artificial persons in cross border transactions UR - http://hdl.handle.net/11427/9614 ER - en_ZA
dc.identifier.urihttp://hdl.handle.net/11427/9614
dc.identifier.vancouvercitationTanyanyiwan V. Establishing the residency of artificial persons in cross border transactions. [Thesis]. University of Cape Town ,Faculty of Law ,Department of Commercial Law, 2014 [cited yyyy month dd]. Available from: http://hdl.handle.net/11427/9614en_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.titleEstablishing the residency of artificial persons in cross border transactionsen_ZA
dc.typeMaster Thesis
dc.type.qualificationlevelMasters
dc.type.qualificationnameLLMen_ZA
uct.type.filetypeText
uct.type.filetypeImage
uct.type.publicationResearchen_ZA
uct.type.resourceThesisen_ZA
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