publication . Thesis . 2014

An international comparative study of South African controlled foreign company legislation

Singh, Krishenduth Phagoo;
Open Access English
  • Published: 01 Jan 2014
  • Country: South Africa
PhD (Tax), North-West University, Potchefstroom Campus, 2014 Globalisation of trade and investment has led multinational enterprises to develop strategies to maximise profits by investing in countries with a favourable tax climate, resulting in loss of tax revenue to domestic economies. In South Africa, recent economic liberalisation and associated relaxation of exchange controls have created increasing exposure to global competition, risk of capital flight and potential threat to the tax base. Heeding OECD recommendations intended to counter negative tax implications for domestic economies and curb harmful tax practices, South Africa introduced controlled forei...
free text keywords: Anti-avoidance tax legislation, Controlled foreign companies, Foreign business establishment, Katz Commission, Mobile foreign income, Model tax treaty, Place of effective management, Resident / non-resident taxpayer, Residence-based tax assessment;, Source-based tax assessment
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