An investigation into whether the South African and Mauritian preferential holding company regimes may undermine fiscal transparency
Master Thesis
2014
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University of Cape Town
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Abstract
Investor interest in the untapped growth offered by the African continent is increasing dramatically. The South African Headquarter Company and the Mauritian Global Business Licence regimes, offer the most expansive double tax treaty networks of all African holding company regimes. Therefore, both of these regimes are attractive to international investors wanting to establish a gateway into Africa. Governments have identified the need to share ownership information in respect of corporations so as to curb base erosion and profit shifting and to prevent fiscal losses arising from unintended deliberate abuse of double tax treaty benefits. This dissertation examines whether Africa's two favourable holding company regimes, the South African Headquarter Company and the Mauritian Global Business Licence, have characteristics and installed measures to ensure the fiscal transparency so desired by the international community at large. The examination commences with a review of features within the Mauritian and South African holding company regimes which perpetuate the concealment of the identities of the owners of these holding companies. Without measures in place to overcome these anonymity features, the Headquarter Company and Global Business Licence corporation regimes would undoubtedly undermine fiscal transparency. Therefore, this dissertation investigates the legal and administrative measures in place to overcome these roadblocks to fiscal transparency. This examination established that sufficient measures are in place to facilitate the recording and maintenance of ownership information for headquarter companies and global business licence corporations.
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Includes bibliographical references.
Reference:
Russell, B. 2014. An investigation into whether the South African and Mauritian preferential holding company regimes may undermine fiscal transparency. University of Cape Town.