Group taxation in South Africa : a contextual analysis

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dc.contributor.advisorCramer, Peteren_ZA
dc.contributor.authorOmar, Shaheenen_ZA
dc.date.accessioned2014-11-05T17:40:43Z
dc.date.available2014-11-05T17:40:43Z
dc.date.issued2009en_ZA
dc.descriptionIncludes bibliographical references (leaves 89-90).en_ZA
dc.description.abstractA group taxation regime can be defined as: "a set of rules that enables corporate taxpayers to compute the tax liability of related corporations on a consolidated or combined basis(.) (and) ... encompasses not only full consolidation. but also tranifer of particular tax allributes between the members (?f a corporate group .. I. This definition is very broad and group taxation could be better understood when considering the more common forms of group taxation such as the group relief regime and the consolidation regime. The consolidation regime generally involves each company within a group of companies computing its own income after which the income is consolidated at the holding company-level for tax purposes. The holding company would thereafter become liable for the group's tax2 , whereas a group relief regime involves the ability of losses incurred by one company in a group of companies to be transferred to another member group company3. Does group taxation exist in South Africa? Based on the above, it would appear not. The more pertinent question that has to be answered is whether or not elements of group taxation currently exist in South African tax legislation. The debate in terms of the introduction of group taxation in South Africa was raised for the first time by the Margo Commission of Inquiry, which ultimately decided against recommending the introduction of group taxation. The Katz Commission of Inquiry however recommended the introduction of group taxation. National Treasury has however failed to act on the Katz Commission's recommendations.en_ZA
dc.identifier.apacitationOmar, S. (2009). <i>Group taxation in South Africa : a contextual analysis</i>. (Thesis). University of Cape Town ,Faculty of Law ,Department of Commercial Law. Retrieved from http://hdl.handle.net/11427/9268en_ZA
dc.identifier.chicagocitationOmar, Shaheen. <i>"Group taxation in South Africa : a contextual analysis."</i> Thesis., University of Cape Town ,Faculty of Law ,Department of Commercial Law, 2009. http://hdl.handle.net/11427/9268en_ZA
dc.identifier.citationOmar, S. 2009. Group taxation in South Africa : a contextual analysis. University of Cape Town.en_ZA
dc.identifier.ris TY - Thesis / Dissertation AU - Omar, Shaheen AB - A group taxation regime can be defined as: "a set of rules that enables corporate taxpayers to compute the tax liability of related corporations on a consolidated or combined basis(.) (and) ... encompasses not only full consolidation. but also tranifer of particular tax allributes between the members (?f a corporate group .. I. This definition is very broad and group taxation could be better understood when considering the more common forms of group taxation such as the group relief regime and the consolidation regime. The consolidation regime generally involves each company within a group of companies computing its own income after which the income is consolidated at the holding company-level for tax purposes. The holding company would thereafter become liable for the group's tax2 , whereas a group relief regime involves the ability of losses incurred by one company in a group of companies to be transferred to another member group company3. Does group taxation exist in South Africa? Based on the above, it would appear not. The more pertinent question that has to be answered is whether or not elements of group taxation currently exist in South African tax legislation. The debate in terms of the introduction of group taxation in South Africa was raised for the first time by the Margo Commission of Inquiry, which ultimately decided against recommending the introduction of group taxation. The Katz Commission of Inquiry however recommended the introduction of group taxation. National Treasury has however failed to act on the Katz Commission's recommendations. DA - 2009 DB - OpenUCT DP - University of Cape Town LK - https://open.uct.ac.za PB - University of Cape Town PY - 2009 T1 - Group taxation in South Africa : a contextual analysis TI - Group taxation in South Africa : a contextual analysis UR - http://hdl.handle.net/11427/9268 ER - en_ZA
dc.identifier.urihttp://hdl.handle.net/11427/9268
dc.identifier.vancouvercitationOmar S. Group taxation in South Africa : a contextual analysis. [Thesis]. University of Cape Town ,Faculty of Law ,Department of Commercial Law, 2009 [cited yyyy month dd]. Available from: http://hdl.handle.net/11427/9268en_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.titleGroup taxation in South Africa : a contextual analysisen_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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