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Zagler, Martin, and Cristiana Zanzottera. "Corporate income taxation uncertainty and foreign direct investment." WU Vienna University of Economics and Business, Universität Wien, 2012. http://epub.wu.ac.at/3767/1/2012_07_Zagler_Zanzottera.pdf.
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This paper analyzes the effects of legal uncertainty around corporate
income taxation on foreign direct investment (FDI). Legal uncertainty can
take many forms: double tax agreements, different types of legal systems
and corruption. We test the effect of legal uncertainty on foreign direct
investment with an international panel. We find that an increase in the
ratio of the statutory corporate income tax rate of the destination relative
to the source country exhibits a negative impact on foreign direct
investment. Interacting the statutory corporate income tax rate with
measures of legal uncertainty, we observe a negative effect.Series: WU International Taxation Research Paper Series
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Wang, Feifei. "Income Distribution, International Trade and Foreign Direct Investment with Heterogeneous Firms." FIU Digital Commons, 2016. http://digitalcommons.fiu.edu/etd/2545.
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This dissertation investigates the factors that firms take into consideration when they decide in which manner to expand internationally (i.e. foreign direct investment and international trade). Another component of the investigation focuses on what types of firms benefit the most and what are the associated benefits with expanding internationally.
I investigate self-selection and learning-by-exporting hypothesis by applying matched sampling techniques and non-structural econometric models. Using a Chinese firm-level dataset, I find that firms that start exporting are more productive than non-exporting ones. Additionally, in most industries exporters become more productive in time.
I then investigate how income inequality leads firms to make different choices on how they expand internationally. I develop a simple theoretical model by carefully choosing a mean-preserving income distribution. I find that changing the mean-preserving parameter of the income distribution affects market demand for firms' products and firms' choosing of strategies for international expansion. Some, but not all firms gain market shares due to larger market size caused by the more concentrated income distribution around the mean. Using Gini coefficient as the proxy for income distribution, I demonstrate empirically that some firms gain market shares and benefit from more consumers becoming part of the middle class due to the corresponding change in income distribution.
I also study the aggregate implication of opening the economy in a two-country Dynamic Stochastic Equilibrium in which firms have heterogeneous productivity in the spirit of Melitz (2003). I show that benefits incurred by international engagement are not equally distributed among firms. I separate firms into four categories based on their productivity levels. The highest productivity firms gain the most by breaking into a new market as multinationals. The second highest productivity firms become exporters and obtain the second largest market share. The third highest productivity firms only serve the domestic market, while the lowest productivity firms exit the market.
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Ong'wamuhana, Kibuta. "The taxation of income from foreign investments : a case study of some developing countries." Title page, contents and abstract only, 1989. http://web4.library.adelaide.edu.au/theses/09LM/09lmo58.pdf.
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Smith, William Nevel. "A critical examination of the income tax provisions relating to the taxation of foreign income of residents as defined." Thesis, Nelson Mandela Metropolitan University, 2004. http://hdl.handle.net/10948/d1019676.
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The Budget speech of 23 February 2000 by the Minister of Finance marked the introduction of significant changes to the income tax system of the Republic of South Africa (Republic). A residence-based system of taxation (RBT) was adopted for years of assessment commencing on or after 1 January 2001 and Capital Gains Tax (CGT) was introduced with effect from 1 October 2001. According to the 2000 Budget Review a move to a residence-based system would significantly broaden the tax base, limit opportunities for tax arbitrage and bring the tax system in line with generally accepted international practice. The relaxation of exchange controls for South African residents with effect from 1 July 1997 made it possible for residents to invest limited funds offshore. The Fifth Interim Report of the Katz Commission suggested that if exchange controls were relaxed, the taxation of active income should remain on a source basis, but that passive income should be taxed on a residence basis. As a result deemed source rules in the form of section 9C and 9D were introduced into the Act with effect from 1 July 1997 and applied to “investment income” as defined. Section 9C taxed investment income of both residents and non-residents (from activities carried on by a permanent establishment in the Republic). Section 9D taxed investment income of controlled foreign entities and investment income arising from donations, settlements or other dispositions in the hands of residents. The taxation of foreign dividends with effect from 23 February 2000 as a first phase in the move to a residence based system, lead to the introduction of s 9E. Foreign Dividends were taxed in the hands of residents subject to certain exemptions. The basic interest exemption was extended to foreign dividends. Section 6quat was revised to extend the rebate to foreign dividends and profits of a company from which dividends were declared. Section 9D was amended to cater for foreign dividends received by or accrued to controlled foreign entities. The implementation of a full residence-based system of taxation with effect from years of assessment commencing on or after 1 January 2001 required amendments to various sections of the Income Tax Act as well as the introduction of new sections. A residence minus system was adopted which means that residents as defined are now taxed on their world- wide income with certain exemptions. Non-residents are taxed on their income from sources within or deemed to be within the Republic. The provisions relating to the taxation of foreign income of residents is complex; adding to the complexity is the fact that several changes have already been made to these provisions since the inception of the world-wide basis of taxation. The provisions must also be interpreted against the background of any double taxation agreement (DTA) between the Republic and the relevant foreign country as the applicable DTA may override the Republic domestic legislation. For purposes of this treatise the amending Acts enacted up to the end of December 2003 are taken into account. Hardly five years after the Katz commission of inquiry into the tax structure concluded that RBT and CGT were too complicated to be administered by SARS, the implementation of RBT and CGT were announced in the 2000 Budget. A detailed examination of the provisions relating to foreign income of residents as defined was undertaken. Interpretational issues to be clarified by legislation and certain planning issues are highlighted. It is essential to understand and carefully consider the Republic tax laws and the relevant double taxation agreements, for the successful application of the provisions. Careful planning before concluding transactions is of vital importance in order to avoid or minimize any unwanted tax consequences resulting from the RBT and CGT provisions.
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Burns, Darren. "Foreign direct investment and population health in low and middle income countries." Thesis, University of East Anglia, 2018. https://ueaeprints.uea.ac.uk/67678/.
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Opinions are divided on the health impacts of multi-national corporations (MNCs), and their foreign direct investment (FDI) projects in low and middle income countries (LMICs). MNCs in LMICs have been associated with unsafe or unsanitary working conditions, pollution, and aggressively marketing of unhealthy foods. This suggests a harmful impact on population health. Yet, FDI also generates employment, income, and growth, implying some benefits to population health. FDI flows may not be the only factor determining their ultimate impact on health. It is currently unclear whether FDI into different industries or whole sectors is related to health impacts, and also whether geographic clustering of FDI is associated with an impact on population health. The relationship between FDI and population health is investigated here, beginning with a systematic review of quantitative literature surrounding international trade and non-nutritional health outcomes. This highlights four important messages: FDI is likely a determinant of health in LMICs; the importance of sample selection and considering heterogeneity; bi-directional causality between FDI and health; and the underuse of individual level datasets to investigate the association. Later chapters seek to respond in different ways to these messages, firstly using instrumental variable methods to investigate FDI and overall population health in LMICs. This indicates FDI to be associated with overall population health benefits, yet provides some evidence that manufacturing FDI is associated with harm. The second study utilises individual level data and spatial techniques to investigate FDI and nutritional health in Chinese adults, indicating that FDI is positively associated with increased BMI amongst Chinese adults. The final study investigates FDI and smoking in Russian adults, suggesting that FDI is associated with increased smoking. Overall, this thesis suggests that FDI has a positive effect in general on overall health, yet is harmful when looking in more specific contexts.
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Nelson, Andrew J. "The spatial relationship of complex foreign direct investment and the effects of foreign direct investment and trade on income." Fairfax, VA : George Mason University, 2008. http://hdl.handle.net/1920/3084.
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Thesis (Ph.D.)--George Mason University, 2008.Vita: p. 159. Thesis director: Carlos Ramírez. Submitted in partial fulfillment of the requirements for the degree of Doctor of Philosophy in Economics. Title from PDF t.p. (viewed July 3, 2008). Includes bibliographical references (p. 151-158). Also issued in print.
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Chen, Chet Sun. "Foreign Direct Investment and proximity : a study of asymmetric technology and income convergence." Thesis, University of Birmingham, 2000. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.368314.
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Bhandari, Bornali. "Essays on foreign direct investment and income inequality and cross-price effects in the U.S. trade balance /." view abstract or download file of text, 2006. http://proquest.umi.com/pqdweb?did=1192186831&sid=2&Fmt=2&clientId=11238&RQT=309&VName=PQD.
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Thesis (Ph. D.)--University of Oregon, 2006.Typescript. Includes vita and abstract. Includes bibliographical references (leaves 116-124). Also available for download via the World Wide Web; free to University of Oregon users.
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Mkabile, Nwabisa. "An analysis of the tax consequences of the double tax agreement between South Africa and the Democratic Republic of Congo." Thesis, Rhodes University, 2015. http://hdl.handle.net/10962/d1017539.
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As a result of the different tax systems adopted by countries, foreign-sourced income earned by taxpayers may be subject to double taxation. This may therefore impede cross-border trade and investment. Double taxation relief is provided unilaterally, in terms of a country’s domestic laws or bilaterally in terms of Double Taxation Agreements. South African residents earning income from the Democratic Republic of Congo may be subject to tax in both countries. To eliminate such double taxation the South African Income Tax Act, No 58 of 1962, provides for unilateral relief from double taxation in the form of exemptions, rebates and deductions. The double tax agreement between South Africa and the Democratic Republic of the Congo came into effect recently and double taxation relief for South African residents is now also available in terms of tax treaty law. The objective of the research was to determine whether the combination of the unilateral measures and the double tax agreement provide relief in respect of all types of income earned by South African residents in the Democratic Republic of the Congo. It was concluded that the double tax agreement, together with the unilateral relief provided for in the Income Tax Act will grant relief for all types of income earned by South African residents in the Democratic Republic of the Congo.
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Khieu, Samphors. "Essays on the impact of aid and institutions on income inequality and human welfare." Diss., Georgia Institute of Technology, 2013. http://hdl.handle.net/1853/53393.
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Billions of dollars in development aid are sent to developing countries every year. Weak institutions in recipient countries are the main impediments often discussed to prevent aid from reaching the intended targets. At the same time, they also hinder aid effectiveness in improving the lives of the people. This dissertation argues that the impact of aid on income distribution and human welfare in recipient countries differs by their institutional quality. Institutions encompass many different dimensions. This dissertation focuses on: corruption in government, quality of bureaucracy, and the rule of law. This study explores the impact in two essays.
The first essay investigates the role of institutions in aid distribution. In particular, we examine the interplay between aid and institutions on income shares of different population groups (measured by income quintiles), and on the gap between the rich and the poor (measured by the Gini coefficient). The study uses Principal Component Analysis to construct an institutional index from the three components: corruption, bureaucratic quality, and the rule of law. Employing Two-Stage Least Squares (2SLS) methodology on a panel data of 85 countries from 1960 to 2004, this study finds that an increase in aid as a percentage of Gross Domestic Product (GDP) decreases the income shares of the poor (quintile 1 and quintile 2), but increases that of the rich (quintile 5), thereby widening the gap between the rich and the poor (Gini coefficient). Contrary to our main hypothesis, though, recipient countries’ institutions do not play any role in aid distribution.
Similarly, the second essay also focuses on the importance of recipient institutions, but it assesses aid effectiveness in improving human welfare. The study considers five human development indicators: the Human Development Index (HDI), the health index, the infant mortality rate, the education index, and the average years of schooling. The study empirically tests the hypothesis by utilizing the same methodology as in the first essay, but on a panel of 80 countries from 1980 to 2004. The findings suggest that human welfare in recipient countries improves as aid increases. The improvement appears to be driven more by the health than the education sector. Furthermore, aid is more effective in countries with poorer institutional quality, which is contrary to the hypothesis. However, the results are not consistent when taking into account government’s pro-poor public expenditure.
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De, Abreu Jeannine Netto. "A suggested interpretation note for section 9D of the Income Tax Act / J.N. De Abrea." Thesis, North-West University, 2010. http://hdl.handle.net/10394/4476.
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Controlled foreign company ('CFC') legislation was introduced in phases to co-incide with South Africa?s move from a source based system to a residence based system. Initially with the introduction of the legislation it was directed at those foreign entities earning passive income. However, over the years the legislation has been amended to include active income of entities and additional aspects to the section have been inserted to provide clarity for taxpayers.
An increase in cross border transactions and offshore investment has necessitated the need to introduce CFC legislation into the revenue codes of many countries, South Africa being one of them.
In most revenue codes where CFC or similar legislation has been introduced it is one of the most complex areas in a country's revenue code (Sandler, 1998:23). This mini-dissertation aims to interpret section 9D and also aims to provide guidance on its application in practice with the help of practical examples and reference to relevant international case law.
The end result of this research is a proposed interpretation note on section 9D which is attached as Appendix 1.Thesis (M.Com. (Tax))--North-West University, Potchefstroom Campus, 2011.
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Fourie, Susanna Janine. "The treatment of section 24J instruments denominated in a foreign currency with regard to the categorisation as fixed or variable rate instruments and the interaction between section 24J, section 25D (foreign currency translation rules) and section 24I (gains and losses on foreign exchange transactions)." Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/18626.
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Section 24J is regarded to be one of the most complex provisions in the Income Tax Act No. 58 of 1962. This study specifically focuses on the income tax treatment of section 24Jinstruments denominated in a foreign currency, specifically with regards to whether such instruments are fixed or variable rate instruments for purposes of section 24J and the interaction between section 24J, section 25D (foreign currency translation rules) and section 24I (gains and losses on foreign exchange transactions).The basic concepts surrounding the incurral and accrual of interest for income tax purposes, as well as of some of the general issues faced when section 24J is practically applied are discussed. Importantly it is found that although the definition of 'instrument' includes all debt instruments, regardless of whether such instruments are interest-bearing, the application of section 24J would have no impact on the issuer or holder of an instrument that is a non-interest bearing debt instrument. Also, the section 24J definition of 'interest' is wider than the common law meaning of the same term. However, as 'interest'is defined with reference to itself, the common law meaning is still very relevant. It is confirmed that section 24J poses various interpretational uncertainties which are especially highlighted when some of the key provisions of section 24J are applied in determining the interest accrual amounts based on the yield to maturity method. Applying the rules of statutory interpretation and with the aid of hypothetical examples, itis argued that foreign exchange rates would fall within the definition of a variable rate for purposes of section 24J. However, an instrument denominated in a foreign currency would be regarded as a fixed rate instrument to the extent that the amounts payable are fixed amounts specified in the applicable foreign currency or the calculation of the amount payable in the applicable foreign currency does not involve the application of a 'variable rate' (as defined).Further is it argued that section 24J merely provides for a single accrual or incurral event during each year of assessment in relation to each instrument. Therefore, where accrual amounts be denominated in a foreign currency it should be translated at the spot rate on the last day of the year of assessment (or on the date of redemption/transfer in the instance where the instrument was transferred/redeemed during the year of assessment) for purposes of determining the sum of the accrual amounts to be included in taxable income. It is also argued that the timing of the accrual and incurral of interest amounts in terms of section 24J is applied in establishing the 'transaction date' of the interest amount owing for purposes of determining 'exchange differences' at the end of any year of assessment in terms of section 24I.
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Mudenda, Lackson Daniel. "Corporate Income Tax Rate and Foreign Direct Investment : The Case of Southern African Economies." Thesis, Umeå universitet, Nationalekonomi, 2015. http://urn.kb.se/resolve?urn=urn:nbn:se:umu:diva-106899.
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Brähler, Katharina. "Controlled Foreign Companies-Rules : eine steuersystematische Analyse im Rahmen eines Ländervergleichs unter Berücksichtigung der Vereinbarkeit mit den Doppelbesteuerungsabkommen und dem europäischen Gemeinschaftsrecht /." Frankfurt am Main ; New York : P. Lang, 2007. http://bvbr.bib-bvb.de:8991/F?func=service&doc_library=BVB01&doc_number=015439584&line_number=0001&func_code=DB_RECORDS&service_type=MEDIA.
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Langlotz, Sarah [Verfasser], and Axel [Akademischer Betreuer] Dreher. "Conflict, Income Shocks, and Foreign Policy: Macro- and Micro-Level Evidence / Sarah Langlotz ; Betreuer: Axel Dreher." Heidelberg : Universitätsbibliothek Heidelberg, 2018. http://d-nb.info/1177149958/34.
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Struwig, Sybrand Johannes. "A comparative study of income tax legislation for foreign oil and gas companies investing in Africa." Diss., University of Pretoria, 2012. http://hdl.handle.net/2263/26424.
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The oil and natural gas industry worldwide has become one of the most important commodities due to its value in use and dependency in our modern lifestyle. Countries with rich oil and natural gas reserves has shown to exploit these resources to the country's economic benefit. South Africa has in the past not been part of the big oil and natural gas producing countries of the world. But recent discoveries of possible shale gas reserves in the Karoo Basin attracted interest by foreign oil and gas companies with the potential that South Africa has as an oil and natural gas producing country. The purpose of this study is to compare the South African income tax law and regulations with that of the Republic of Equatorial Guinea, which arguable can be seen as one of the world's big oil and natural gas producing countries. The study firstly develops an understanding of each of the two countries' oil and natural gas industries and thereafter compares the two countries income tax laws, the income tax system and collection method of the income tax revenues. The study then concludes on the status of the South African income tax regime in comparison to the Republic of Equatorial Guinea's income tax regime. The introduction of the Tenth Schedule to the South African Income Tax Act (58/1962) has brought the income tax laws in South Africa in line with international practice. Consideration should be given to broadening the income tax revenue collection methods in order to broaden the tax base for South Africa. AFRIKAANS : Die olie en natuurlike gas industrie wêreldwyd het een van die mees belangrike kommoditeite geword as gevolg van die waarde en afhanklikheid wat dit het vir ons moderne leefstyl. Lande met ryk olie en natuurlike gas reserwes het bewys dat die gebruik daarvan tot voordeel van 'n land se ekonomiese groei kan lei. Suid-Afrika het in die verlede nie as een van die wêreld se reuse in olie en natuurlike gas produksie getel nie. Maar met die onlangse ontdekking van moontlike skalie gas reserwes in die Karoo Kom het belangstelling van buitelandse olie en gas maatskappye gelok in die potensiaal wat Suid-Afrika het om 'n olie en natuurlike gas produserende land te wees. Die doel van die studie is om 'n vergelyking te tref tussen Suid-Afrika se inkomste belasting wette en regulasies met die van die Republiek van Equatoriaal Guinea, wat gesien kan word as een van die reuse van die wêreld as dit kom by olie en natuurlike gas produserende lande. Die studie skets eerstens 'n agtergrond van die twee lande se olie en natuurlike gas industrieë en daarna vergelyk die studie die twee lande se inkomste belasting wette, die inkomste belasting stelsels en invorderings metodes van die inkomste belasting. Die studie kom dan tot 'n gevolgtrekking oor die status van die Suid-Afrikaanse inkomste belasting omgewing teenoor die Republiek van Equatoriaal Guinea se inkomste belasting omgewing. Die bekendstelling van die Tiende Skedule tot die Inkomste Belasting Wet (58/1962) het die Suid-Afrikaanse inkomste belasting wet in lyn gebring met internasionale inkomste belasinvorderings metodes van die inkomste belasting te verbreed om sodoende die belastingbasis te vergroot.ting wette. Oorweging moet geskenk word aan die invorderings metodes van die inkomste belasting te verbreed om sodoende die belastingbasis te vergroot.Dissertation (MCom)--University of Pretoria, 2012.
Taxation
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Castoe, Minna, and Aalekhya Sanyal. "The Impact of Immigration on Income Inequality : Evidence from Sweden and the United States." Thesis, Mälardalens högskola, Akademin för ekonomi, samhälle och teknik, 2019. http://urn.kb.se/resolve?urn=urn:nbn:se:mdh:diva-44069.
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This paper studies data from a 25-year period in the history of Sweden and the US, ranging from 1993 to 2017. The aim of the thesis was to investigate the impact of immigration on the income inequality of the respective countries while also considering the impact of other specific variables. In order to estimate the impact of the variables, both static and dynamic models were used, with the Gini coefficient being the dependent variable. With the ordinary least square giving short-run estimates and the error correction model providing short- and long- run estimates simultaneously, the main variable for immigration, being the foreign-born population, showed a strong positive relationship with income inequality. For the estimation, the immigration variable was also split into high- and low-skilled immigrants as well as different age groups. In conclusion, we find that immigration in Sweden and the US has high levels of influence on the income inequality for both countries.
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Louis, Henock. "The relevance of the foreign translation adjustment and the effects of dirty surplus items on net income." Connect to resource, 2001. http://rave.ohiolink.edu/etdc/view.cgi?acc%5Fnum=osu1261402308.
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Jin, Zhe. "The legal environment of corporate income taxation for FDI in China : policy, changes, risks." Thesis, University of British Columbia, 2007. http://hdl.handle.net/2429/32138.
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Foreign direct investment (FDI) was unknown to Chinese people before the opening policy in 1979, but since then China's economy has been surging ahead in the past twenty eight years. As one aspect of the FDI policy, I focused on the corporate taxation field to be my research interest, and the topic of my thesis.
In the thesis, the reader will learn how FDI developed in China and degree of FDI development. Also, I provide the reader with China's tax system and policy-oriented in as much detail as possible, most of which is the tax incentive policy towards the FDI in China. However, the policies and incentives raise some issues. As the result of offering FDI tax preference, Chinese government tax revenue as a percentage of GDP has been declining steadily. Problems such as tax avoidance and evasion, and local "fake" FDI entities are getting serious.
The new Corporate Income Tax Law of the People's Republic of China (CIT Law) was passed by the PRC National People's Congress on March 16 2007 and will take effect on January 2008. When China entered into the World Trade Organization (WTO) in 2001, compliance with the general rules required China improve its tax system as soon as possible. The CIT law section in the thesis includes the policy-changing behind the legislation and expected influence on the FDI in China in the future. As a result of the changes to be brought about by the CIT Law, foreign and domestic business in China must adapt to the new tax regime, and I offer some recommendations in that regard.Law, Peter A. Allard School of
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Wiese, Adelle. "Artikel 9C van die inkomstebelastingwet met spesiale verwysing na aktiewe en passiewe inkomste." Thesis, Stellenbosch : Stellenbosch University, 1998. http://hdl.handle.net/10019.1/50898.
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Thesis (MComm)--Stellenbosch University, 1998.ENGLISH ABSTRACT: In the Fifth Interim Report of the Katz Commission recommendations were made on a number of fundamental tax issues, including the distinction between the source and residence principle. The Commission decided that the source principle should remain but that a distinction between "active" and "passive" income should be made. "Active" income should then be taxed on the source principle and "passive" income on the residence principle. With effect from 1 July 1997 exchange controls for South African residents were softened, which meant that South Africans could thereafter invest in foreign countries to a limited extent. To protect the South African tax base, sections 9C and 90 were incorporated in the Income Tax Act with effect from 1 July 1997. Section 9C regulates the taxation of investment income earned in foreign countries. The main purpose of this study was to investigate the taxation of foreign investment income in South Africa. For this purpose a critical analysis of section 9C was done within the context of the recommendations made by the Katz Commission in their Fifth Report. The focus of the study was aimed at the requirements for the exclusion of so-called active investment income according to section 9C(3)(a). In the analysis of section 9C it was necessary to determine where the terms used in the section were derived from. The terms which are not new in the South African tax context were analysed based on the opinions of tax specialists and national case law. The terms which are new in the South African tax context were mostly derived from international models of tax conventions and foreign tax codes. These were analysed according to the use thereof mainly in the Model Tax Convention on Income and on capital of the Organisation for Economic Co-operation and Development and the Commentaries thereon. The critical analysis of section 9C also included the applicability of the section on other sections in the Income Tax Act, a brief commentary on section 90 and the relief provided to taxpayers where the section leads to double taxation. The ability of the South African Revenue Service to collect the tax, the effect of the tax on immigrants and the effect of the electronic future on the tax were also investigated. The conclusion arrived at in this study is that most of the terms in section 9C are based on internationally used terms and could be analysed according to international tax conventions and case law. The South African Revenue Service will have to provide guidelines for the uncertainties and provide measures to rectify the irregularities and inconsistencies found in the section. In the light of further examinations to be done by the South African Revenue Service, based on the recommendations of the Katz Commission in their Fifth Report, section 9C provides a set of internationally accepted principles as a solid base for future regulation.
AFRIKAANSE OPSOMMING: Die Katz-kommissie het in die Vyfde Interim Verslag aanbevelings aangaande 'n aantal fundamentele belastingkwessies, insluitend die onderskeid tussen die bron- en verblyf-grondslag, gemaak. Die Kommissie het tot die gevolgtrekking gekom dat die bron-grondslag behou moet word, maar dat daar 'n onderskeid tussen "aktiewe" en "passiewe" inkomste gemaak moet word. "Aktiewe" inkomste moet dan op die bron-grondslag belas word en "passiewe" inkomste op die verblyf-grondslag. Met ingang 1 Julie 1997 is die valutabeheermaatreels vir Suid-Afrikaanse inwoners verslap wat beteken het dat Suid-Afrikaners voortaan tot 'n beperkte mate in die buiteland beleggings kan maak. Om die Suid-Afrikaanse belastingbasis in die tussentyd te beskerm is artikels 9C en 9D met ingang 1 Julie 1997 tot die Wet gevoeg. Artikel 9C reguleer die belasting van beleggingsinkomste uit buitelandse bronne. Die hoofdoel van hierdie studie was om die belasting van beleggingsinkomste uit buitelandse bronne in Suid-Afrika te ondersoek. 'n Kritiese analise van artikel 9C is gedoen binne die konteks van die voorstelle gemaak deur die Katz-kommissie in die Vyfde Verslag. Die klem van die studie het op die vereistes vir die uitsluiting van sogenaamde aktiewe beleggingsinkomste in artikel 9C(3)(a) geval. Tydens die ontleding van artikel 9C was dit noodsaaklik om vas te stel waar die terme wat in die artikel gebruik is, ontstaan het. Die terme wat nie vir die eerste maal in die Suid-Afrikaanse belastingkonteks gebruik is nie, is ontleed na aanleiding van die menings van Suid-Afrikaanse belastingspesialiste en nasionale regspraak. Die nuwe terme kom meesal in internasionale modelle van belastingkonvensies en buitelandse belastingkodes voor. Die terme is hoofsaaklik ontleed na aanleiding van die gebruik daarvan in die Model Tax Convention on Income and on capital of the Organisation for Economic Cooperation and Development. Die kritiese ontleding van artikel 9C het die toepaslikheid van die artikel op ander afdelings in die lnkomstebelstingwet, 'n kortlikse verwysing na artikel 9D en die verligting beskikbaar aan belastingpligtiges ten opsigte van dubbele belasting, ingesluit. Die invorderbaarheid van die belasting, die effek van die belasting op immigrante en die effek van die elektroniese toekoms op die belasting is ook ondersoek. Die slotsom waartoe die skrywer in hierdie studie gekom het, is dat meeste van die begrippe in artikel 9C internasionaal verstaanbaar is en ontleed kon word, wat die Wet wereldwyd meer aanvaarbaar en verstaanbaar behoort te maak. Die Suid-Afrikaanse lnkomstediens sal egter riglyne ten opsigte van die onduidelike begrippe moet verskaf en die nodige ongelykhede en inkonsekwenthede in die Wet moet regstel. In die lig van verdere ondersoeke deur die Suid-Afrikaanse lnkomstediens, na aanleiding van die voorstelle deur die Katz-kommissie in die Vyfde Verslag, verskaf artikel 9C 'n stel internasionaal aanvaarde beginsels waarop toekomstige regulasies gebaseer sal kan word.
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Stockhammer, Engelbert, Özlem Onaran, and Stefan Ederer. "Functional income distribution and aggregate demand in the Euro-area." Inst. für Volkswirtschaftstheorie und -politik, WU Vienna University of Economics and Business, 2007. http://epub.wu.ac.at/346/1/document.pdf.
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An increase in the wage share has contradictory effects on the subaggregates of aggregate demand. Private consumption expenditures ought to increase because wage incomes typically are associated with higher consumption propensities than capital incomes. Investment expenditures ought to be negatively affected because investment will positively depend on profits. Net exports will be negatively affected because an increase in the wage share corresponds to an increase in unit labor costs and thus a loss in competitiveness. Theoretically aggregate demand can therefore be either wage led or profit led depending on how these effects add up. The results will crucially depend on how open the economy is internationally. The paper estimates a Post-Kaleckian macro model incorporating these effects for the Euro area and finds that the Euro area is presently in a wage-led demand regime. Implications for wage policies are discussed. (author's abstract)Series: Department of Economics Working Paper Series
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Guo, Ting. "Differences in income and consumer expenditure patterns between foreign and American graduate students at Virginia Polytechnic Institute and State University." Thesis, This resource online, 1991. http://scholar.lib.vt.edu/theses/available/etd-08142009-040421/.
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Van, Schaik Rozelle. "A critical analysis of the concepts permanent establishment and foreign business establishment." Thesis, Stellenbosch : Stellenbosch University, 2010. http://hdl.handle.net/10019.1/21139.
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Thesis (MAcc)--Stellenbosch University, 2010.ENGLISH ABSTRACT: The Income Tax Act, Act 58 of 1962 (‘the Act’) currently defines a permanent establishment in section 1. The definition of a permanent establishment in the Act refers to article 5 of the Model Tax Convention on Income and on Capital of the Organisation for Economic Co- Operation and Development. The existence of a permanent establishment in a tax jurisdiction determines the right of the jurisdiction to tax the profits of the permanent establishment. The concept foreign business establishment was inserted into section 9D of the Act by clause 10(1)(a) of the Revenue Laws Amendment Act, Act 59 of 2000. Section 9D is an antiavoidance provision, which determines that certain foreign-sourced income generated by South African controlled foreign companies are subject to tax in South Africa. The concept foreign business establishment is one of the exclusions from the anti-avoidance provisions in section 9D. The Revenue Laws Amendment Act, Act 59 of 2000, replaced all references to the concept permanent establishment with a reference to the newly introduced concept foreign business establishment in section 9D(9)(b) of the Act. The Explanatory Memorandum on the Revenue Laws Amendment Bill, 2000 (SARS 2000:1-12) does not provide a reason for the replacement of the concept permanent establishment. The objective of this study was to analyse and compare the concepts permanent establishment and foreign business establishment in order to make recommendations regarding the required additions and amendments to replace the concept foreign business establishment with the internationally recognised and accepted concept permanent establishment. The proposed replacement of the concept foreign business establishment with an internationally recognised and accepted tax concept will enhance the international compatibility of the Act. The use of an internationally recognised and accepted tax concept will provide clarity and certainty regarding the tax implications of section 9D(9)(b) for those affected by it. It was found that the concepts permanent establishment and foreign business establishment are used in different contexts within the Act. The concepts also apply to different types of taxpayers in different situations. The two concepts have, however, the same objective, being the identification of criteria for the existence of legitimate and substantive business activities in the foreign tax jurisdiction. A comparison between the definitions of the two concepts reveals that there are various components in the definitions with the same wording and meaning. After a detailed comparison between the two definitions it was found that, subject to some suggested additions and amendments, the internationally recognised and accepted concept permanent establishment can replace the concept foreign business establishment in section 9D(9)(b) of the Act without having a material impact on the objective of section 9D(9)(b). This replacement is possible due to the mutual objective of and similar components contained in the definitions of the concepts permanent establishment and foreign business establishments.
AFRIKAANSE OPSOMMING: Die Inkomstebelastingwet, Wet 58 van 1962 (‘die Wet’) definieer ’n permanente saak in artikel 1. Die definisie van ’n permanente saak verwys na artikel 5 van die ‘Model Tax Convention on Income and on Capital of the Organisation for Economic Co-Operation and Development’. Die bestaan van ’n permanente saak in ’n belastingjurisdiksie bepaal die reg van die belastingjurisdiksie om die winste van die permanente saak te belas. Die begrip buitelandse besigheidsaak is deur artikel 10(1)(a) van die Wysigingswet op Inkomstewette, Wet 59 van 2000 in die Wet ingesluit. Artikel 9D is ’n teenvermydingsbepaling wat bepaal dat sekere inkomste vanaf ’n buitelandse bron gegenereer deur ’n Suid-Afrikaans beheerde buitelandse maatskappy in Suid-Afrika belas word. Die begrip buitelandse besigheidsaak is een van die uitsluitings van die teenvermydingsbepaling in artikel 9D. Alle verwysings in artikel 9D(9)(b) na die begrip permanente saak is deur die Wysigingswet op Inkomstewette, Wet 59 van 2000, vervang met ’n verwysing na die nuwe begrip buitelandse besigheidsaak. Die ‘Explanatory Memorandum on the Revenue Laws Amendment Bill, 2000’ (SARS 2000:1-12) verskaf nie ’n rede vir die vervanging van die begrip permanente saak nie. Die doel van die studie was om die begrippe permanente saak en buitelandse besigheidsaak te vergelyk sodat voorstelle gemaak kan word rakende die nodige byvoegings en wysings om die begrip buitelandse besigheidsaak met die internasionaal aanvaarde en erkende begrip, permanente saak, te vervang. Die voorgestelde vervanging van die begrip buitelandse besigheidsaak met ’n internasionaal aanvaarde en erkende begrip sal die internasionale verenigbaarheid van die Suid Afrikaanse wetgewing bevorder. Die gebruik van ’n begrip wat internasionaal aanvaar en erken word, sal sekerheid en duidelikheid bewerkstellig vir diegene wat deur die artikel geaffekteer word. Daar is bevind dat die begrippe permanente saak en buitelandse besigheidsaak in die Wet in verskillende verbande gebruik word. Die begrippe is ook van toepassing op verskillende belastingbetalers in verskillende situasies. Die twee begrippe het egter dieselfde doelwit naamlik die identifisering van kriteria vir die bestaan van wesenlike en volwaardige besigheidsaktiwiteite in die buitelandse belastingjurisdiksie. ’n Vergelyking tussen die definisies van die twee begrippe toon dat verskeie komponente van die definisies dieselfde woorde en betekenis bevat. Na ’n detail vergelyking van die twee begrippe is daar bevind dat, onderhewig aan sommige voorgestelde byvoegings en wysigings, die internasionaal erkende en aanvaarde begrip permanente saak die begrip buitelandse besigheidsaak in artikel 9D(9)(b) van die Wet kan vervang. Die vervanging is moontlik weens die gemeenskaplike doelwit en soortgelyke komponente in die definisies van die begrippe permanente saak en buitelandse besigheidsaak.
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Naidoo, Linton. "An analysis of the effect of the amendments to the taxation of foreign non-South African employment income." Master's thesis, Faculty of Law, 2019. http://hdl.handle.net/11427/30915.
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When South Africa moved from a source based to a residence based system of taxation on 1 March 2001, all South African residents were now being subject to tax on their world-wide income. Residents working outside the Republic were then at risk of being taxed twice on the employment income derived because of South Africa’s residence basis system of taxation. The section 10(1)(o)(ii) of the Income tax Act No. 58 of 1962 (“IT Act”) exemption was the relief mechanism for residents to prevent the possibility of double taxation on the employment income derived from working outside the Republic. As from the 1st of March 2020, Parliament has amended section 10(1)(o)(ii) of the IT Act. The section is amended so that foreign employment income should not be fully exempt in the hands of a resident. Section 10(1)(o)(ii) of the IT Act currently exempts in full, the foreign employment income derived by a resident subject to certain requirements as per the section. The amendment seeks to exempt the first one million rand (R1m) of a residents’ employment income earned outside of the Republic. Foreign employment income in excess of R1m will be taxed in the Republic, applying the normal tax tables for that particular year of assessment. All other requirements of section 10(1)(o)(ii) will not be affected by the amendment, therefore residents will still be required to fulfil the other requirements of the section such as to spend more than 183 and at least 60 continuous full days outside of the Republic rendering employment services during any 12-month period in order to qualify for the exemption. The primary reason for the amendment of section 10(1)(o)(ii) is to prevent situations where employment income is neither taxed in the foreign country nor in South Africa, i.e. double non-taxation, or where foreign taxes are imposed at a significantly reduced rate on employment income derived from working outside the Republic. The amendment of section 10(1)(o)(ii) exemption will negatively affect a resident earning in excess of R1m and working in a tax free or low tax jurisdiction. There are a few alternatives available to affected residents working outside the Republic such as: 1. Seek relief via section 6quat of the IT Act, which is a tax credit on foreign taxes paid. 2. Apply the relevant Articles of a Double Taxation Agreement (“DTA”) between South Africa and a source country in order to seek relief for juridical double taxation. 3. Immigrate and become a non-resident, which will trigger a deemed disposal for capital gains tax purposes in terms of section 9H(2) of the IT Act.
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Lackson, Daniel Mudenda. "Pollution, Electricity Consumption, and Income in the Context of Trade Openness in Zambia." Thesis, Umeå universitet, Nationalekonomi, 2016. http://urn.kb.se/resolve?urn=urn:nbn:se:umu:diva-124715.
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This paper examines the Environmental Kuznets Curve (EKC) hypothesis and tests for causality using Dynamic Ordinary Least Squares (DOLS) and the Vector Error Correction Model (VECM). There is evidence of long-run relationships in the three models under consideration. The Dynamic Ordinary Least Squares (DOLS) finds no evidence to support the existence of an environmental Kuznets curve (EKC) hypothesis for Zambia in the long-run. The evidence from the long-run suggests an opposite of the Environmental Kuznets Curve (EKC), in that the results indicate a U-shaped curve relationship between income and carbon emission. The conclusion on causality based on the VECM is that there is evidence of neutrality hypothesis between either total electricity and income or between industrial electricity and income in the short-run Additionally, there is evidence of conservation hypothesis in the context of residential and agricultural electricity consumption.
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Asif, Farah [Verfasser], Dieter [Akademischer Betreuer] Bender, and Wilhelm [Akademischer Betreuer] Löwenstein. "Impact of foreign affiliation on the livelihood of low-income rural households / Farah Asif. Gutachter: Dieter Bender ; Wilhelm Löwenstein." Bochum : Ruhr-Universität Bochum, 2016. http://d-nb.info/109588400X/34.
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Silveira, Florencia. "The Influence of Foreign-Born Population on Immigrants' Academic Achievement: A Multilevel Analysis of Students in High-Income Countries." BYU ScholarsArchive, 2018. https://scholarsarchive.byu.edu/etd/6796.
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Scholars have linked multiple background characteristics to academic achievement; among these are student SES and race/ethnicity. A largely understudied student characteristic in relation to academic achievement is student immigrant status. I contextualize this relationship by considering a macro social setting: country-level foreign-born population. To do this, I examine mathematics achievement from the 2015 PISA assessment in 41 high-income countries. Using mixed-effects modeling, I examine student- and country-level factors and their effects on mathematics achievement. I use within- and cross-level interactions to examine the relationship between 1) immigrant status and student SES and between 2) immigrant status and foreign-born population. To examine the relationship between student immigrant status and student SES and between immigrant status and foreign-born-population, I use within- and cross-level interactions. My findings indicate that immigrant students perform similarly to native-born students when considering other contextual factors at the student-, school-, and country- levels. Furthermore, SES moderates the effect of immigrant status, with second-generation immigrants exhibiting a smaller achievement gain with increased SES. Additionally, everyone – immigrants and non-immigrants alike – benefits from higher foreign-born population rates, suggesting that immigration is advantageous for all students.
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Wessels, Jacques. "The tax implications of non-resident sportspersons performing and earning an income in South Africa." Thesis, Rhodes University, 2008. http://hdl.handle.net/10962/d1003719.
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As the number of non-resident sports persons competing in South Africa increases so does the need to tax them more effectively. It was for this reason that the South African legislature decided to insert Part IlIA into the Income Tax Act which regulates the taxation of non-resident sports persons in South Africa. The new tax on foreign sports persons, which came into effect during August 2006, is a withholding tax placing the onus upon the organizer of the event to withhold the tax portion of the payment to the non-resident sportsperson and pay it over to the revenue services. The rate of taxation has been set at 15 percent on all amounts received by or accruing to a foreign sportsperson. The question which the research addressed is whether this new tax will prove to be an effective tax, both from the point of view of its equity and the administration of the tax. In order to determine the impact of the new tax, it was compared to similar taxes implemented in the United Kingdom and Australia and also to other withholding taxes levied in South Africa. The new tax was also measured against a theoretical model for effectiveness, compared to the pre-August 2006 situation and to the taxation of resident sportsmen and women, using hypothetical examples. The major shortcomings of the new withholding tax are the uncertainty with regard to the intention of the legislature on matters such as the taxation of capital income versus revenue income, the question whether payments to support staff are included in the ambit of the new tax, the taxation of the award of assets in lieu of cash payments and the definition of a resident. A further area of concern is that the rate of taxation of 15 percent appears to be too low and creates horizontal inequity between the taxation of resident and non-resident sports persons. The new tax on non-resident sports persons may have its shortcomings but, depending upon the administrative and support structures put in place to deal with it, will be an effective tax. The rate at which the tax is levied could result in a less tax being collected than before but, with the reduced administrative cost of tax collection, the effective/statutory ratio of the tax could well be much higher than it was. This is a new tax in South Africa and certain initial problems are inevitable and will undoubtedly be solved as the administrators gain experience and as the case law governing this tax develops.KMBT_363
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Ngo, Ngoc Qui. "FDI and Economic Growth : An Empirical Study of Lower-middle Income Economies." Thesis, Högskolan i Jönköping, Internationella Handelshögskolan, 2019. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-44025.
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Within a panel data context with fixed effects method, using data on a sample of 40 lower- middle income economies, this paper investigates whether and to what extent FDI stimulates economic growth over the period 2007-2017. The main finding of this paper highlights the complementary effects between FDI and education, suggesting that a certain level of education must be reached in order for FDI to contribute positively on economic growth. Further, the level of education in this sample set is below the level that is considered as adequate in order to spur economic growth and thus this affects the absorptive capacity. This paper can only confirm that there is a certain association between FDI and economic growth and cannot confirm the widespread belief that FDI stimulates economic growth due to that the estimated models more often than not provided insignificant results.
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Antenucci, Joseph William. "An investigation of the effects of complexity in federal income tax laws on the compliance of nonresident students." Diss., This resource online, 1993. http://scholar.lib.vt.edu/theses/available/etd-06062008-171754/.
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Schendra, Mihai, and Aleksandar Zahariev. "The Corporate Tax Effect on Inflows of Foreign Direct Investment: The case of OECD countries." Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Economics, Finance and Statistics, 2011. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-15977.
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There is a reasonable amount of literature and discussions among scholars on the effect of host country corporate taxation on the inflows of foreign direct investment (FDI). This study is an attempt to analyse this effect in 25 high income OECD countries over the period of 1996 until 2009. The main objective of the paper is to prove statistically whether there is significant and negative relationship between the inflows of FDI and corporate taxation in the selected sample of OECD countries during the specified time span. This relationship is investigated with OLS regression analysis with pooled panel data to find to what extent the selected explanatory variable effective tax rate (ETR) along with trade openness, long term interest rate, share of internet users and labour cost have an impact on the dependent variable - FDI relative to GDP. Finally, it is proved that the elasticity between corporate taxation and FDI is positive at a level below the average effective tax rate and negative above the average level of effective tax rate. In addition, all other important variables included in the regression model are found to be significant determinants of FDI. The study is based on relevant literature and the statistical analysis is made in regard to the models described in scientific articles in the paper.
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Granath, Magdalena, and Maren Sluiter. "Do property rights matter to FDI? : A cross-sectional study of property rights, institutions and FDI in middle income countries." Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Nationalekonomi, 2018. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-40187.
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Property rights are an important subject of economic theory and as a product of institutional qualities an essential determinant of Foreign Direct Investment (FDI). The purpose of this study is to examine how middle income countries with, on average, weak property rights can attract investments from abroad, given their (formal) institutions, and if differences in institutional qualities have an effect on FDI inflows. Using a panel approach to observe a sample of 20 countries over ten years, we find that there is mixed evidence supporting this theory. Whilst the theoretical background suggests that institutional qualities do affect a country’s ability to attract or deter investments, we cannot conclude a significant effect in our results. Furthermore, the study concludes that certain products of institutional qualities (democracy, corruption) can lead to mixed effects on the net inflows of FDI, but that an important determinant is the market-size of the country.
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Zagrajczuk-Ray, Anna. "The economy of multinationals : essays on international trade, income inequality and strategies of multinational firms." Thesis, Paris 1, 2016. http://www.theses.fr/2016PA01E013.
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Cette thèse analyse les stratégies des firmes multinationales dans leurs différentes dimensions et évalue leur effet sur les consommateurs et travailleurs. Les essaies consécutifs s'intéressent aux choix d'expansion des FMNs, leur décision de délocalisation de production, leurs stratégies de l'investissement direct à l'étranger (IDE) au niveau agrégé, ainsi que les pratiques de la discrimination de prix sur les marchés aux fortes inégalités de revenuThis thesis examines both theoretically and empirically strategies of multinational firms in their various dimensions and evaluates their impact on consumers and workers. The following essays look at MNEs' product expansion choices, their production localization decisions, foreign direct investment strategies (FOI) at the aggregate level and, finally, price discrimination practices on more unequal markets
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Araujo, Manuel antonio Alculete Lopes De. "Promoting empl;oyment, income and labour standards through foreign direct investment in post-war Mozambique - the cases of Dunavant and Mozal." Thesis, University of East Anglia, 2009. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.533714.
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Brähler, Katharina. "Controlled Foreign Companies-Rules : eine steuersystematische Analyse im Rahmen eines Ländervergleichs unter Berücksichtigung der Vereinbarkeit mit den Doppelbesteuerungsabkommen und dem Europäischen Gemeinschaftsrecht /." Frankfurt am Main [u.a.] : Lang, 2006. http://www.gbv.de/dms/zbw/518363880.pdf.
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Luo, Ji. "Liquidity timing skills for hedge funds." Thesis, Loughborough University, 2015. https://dspace.lboro.ac.uk/2134/18999.
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In the thesis, we investigate whether hedge fund managers have liquidity timing skills in the fixed income market, foreign exchange market and commodity market, respectively. Managers with the liquidity timing skills can strategically adjust hedge funds exposure to the target financial market based on their forecasts about the future changes in market liquidity. We find empirical evidence that hedge funds in certain categories have the skills to time the liquidity levels in the fixed income market, foreign exchange market and commodity market. We conduct a range of robustness tests, which show that hedge funds still exhibit liquidity timing skills after controlling for the factors that may affect timing ability. In particular, our findings are robust to the usage of leverage, funding constraints, investor redemption restrictions, hedge funds trades on market liquidity, financial crisis, hedge fund data biases, market return and volatility timing, liquidity risk factor, systematic stale pricing and option factors. We also conduct bootstrap analysis to ensure the results are not dependent on the normality assumption. Our investigation is helpful to understand the importance of market liquidity to hedge funds professional portfolio management.
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Mphaka, Patrick. "Strategies for Reducing Microfinance Loan Default in Low-Income Markets." ScholarWorks, 2017. https://scholarworks.waldenu.edu/dissertations/4391.
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Poor loan repayment causes the decline and failure of some microfinance institutions. The purpose of this qualitative multiple case study was to explore strategies that microfinance (MFI) leaders use to reduce loan default in the base of the pyramid market. The study population included 6 MFI leaders, 12 borrower community-based groups, and 4 staff members of the Adventist Development and Relief Agency (ADRA Rwanda) who reduced MFI loan default in Rwanda. Data were collected through semistructured interviews with 3 MFI leaders, 3 ADRA Rwanda staff members, and 3 members of borrower groups. Data were also collected through focus groups with 3 borrower community-based groups comprising 6 to 8 members. Additional data were collected through the analysis of MFI and ADRA Rwanda organizational documents. The Varian group lending model was the conceptual framework for the study. Data analysis involved methodological triangulation and the Gadamerian hermeneutics framework of interpretation. Four major themes emerged: intrapreneurship and environmental business opportunities, favorable loan repayment conditions, strategies for choosing borrower groups, and loan use monitoring. A sustainable microfinance institution can produce social change by providing microfinance loans that clients can use to start and grow microenterprises that can become the source of income for improving the lives of clients and their family members. Findings may also be used to create economic growth through the participation of more people in economic activities in the base of the pyramid market.
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Brennan, Kerry Jane. "Is All FDI Created Equal?: An Empirical Analysis of the Effect of Foreign Direct Investment and its Sectoral Destination on Income Inequality in Developing Countries." Thesis, Boston College, 2007. http://hdl.handle.net/2345/522.
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Thesis advisor: Robert G. MurphyIncome inequality is an issue of moral, ethical, and economic concern. Disparity in levels of wealth and income in developing countries prevents poor individuals from enjoying the same opportunities as their wealthier counterparts, and hinders the prospects for future development. FDI is one among several possible culprits responsible for increasing income inequality. As a representative of foreign control and influence in developing economies, some countries are wary of FDI. On the other hand, FDI brings the promise of jobs, technology spillovers, foreign exchange, and economic growth. Previous studies have explored the effects of FDI on income inequality in developing countries, but they have all relied on FDI data that does not distinguish between direct investment destined for the primary, secondary, and tertiary sectors. This study uses sectorally disaggregated FDI data for a sample of developing countries over the years 1990-2005 in an attempt to discern whether sector-specific features play a role in affecting domestic income inequality. While this study fails to find the FDI variables significant, it does find much support for other possible causes of income inequality, such as population growth rate and levels of urbanization within a country
Thesis (BA) — Boston College, 2007
Submitted to: Boston College. College of Arts and Sciences
Discipline: International Studies
Discipline: College Honors Program
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Stockhammer, Engelbert, Eckhard Hein, and Lucas Grafl. "Globalization and the effects of changes in functional income distribution on aggregate demand in Germany." Inst. für Volkswirtschaftstheorie und -politik, WU Vienna University of Economics and Business, 2007. http://epub.wu.ac.at/1104/1/document.pdf.
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Germany has experienced a period of extreme nominal and real wage moderation since the mid 1990s. Contrary to the expectations of liberal economists this has failed to improve Germany's mediocre economic performance. However, Germany is now running substantial current account surpluses. One possible explanation for Germany's disappointing performance is found in Kaleckian theory, which highlights that the domestic demand effect of a decline in the wage share will typically be contractionary, whereas net exports will increase (Blecker 1989). The size of the foreign demand effect will critically depend on the degree of openness of the economy. The paper aims at estimating the demand side of a Bhaduri-Marglin (1990) -type model empirically for Germany. The paper builds on the estimation strategy of Stockhammer, Onaran and Ederer (2007) and Hein and Vogel (2008a, 2008b). The main contribution lies in a careful analysis of the effects of globalization. Since Germany is a large open economy by now it is a particularly interesting case study. (author´s abstract)Series: Department of Economics Working Paper Series
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Wu, Yi-Tsung. "Essays on international investment holdings and risk sharing." Diss., Online access via UMI:, 2007.
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Lappas-Grigoraki, Daphni. "Tax Non-Compliance In Developing Countries: Examining The Effect On Foreign Direct Investment, Infrastructure And Transfer Pricing." Scholarship @ Claremont, 2014. http://scholarship.claremont.edu/cmc_theses/925.
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This paper will discuss the obstacles governments of developing countries face in regulating related party transactions in this rapidly globalizing world. The first section of this paper will focus on foreign direct investment, its benefits, and the tax incentives instituted by developing countries to attract the capital of multinational corporations. Next, this paper will examine the major obstacles to growth a developing country must combat: shadow economies and corruption. These two enemies of growth hurt a developing country’s ability to attract foreign direct investment, to develop its rule of law and tax administration, and to efficiently allocate its resources with the goal of developing a stable economy. Finally, I will explain the difficulties developing countries must overcome to regulate firm transfer pricing under the current global standard.
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Costa, David Patrick Anthony. "Taxing recurrent services rendered by a foreign company to an associated enterprise in South Africa." Thesis, Rhodes University, 2013. http://hdl.handle.net/10962/d1008269.
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The objective of the study was to investigate the right of the South African Government to tax the income earned by a foreign company when rendering services in South Africa to a South African associated enterprise on a recurrent basis, together with the right to tax the amounts paid to the employees of the permanent establishment for services rendered in South Africa. At the same time the research investigated whether the services rendered by a foreign company to an associated enterprise in South Africa on a recurrent basis would constitute a permanent establishment, as this is essential before South Africa may tax either the foreign company or the employees of the permanent establishment (where such employees are not resident in South Africa).The research was conducted by means of a critical analysis of documentary data and data from a limited number of interviews with academics and the authors of textbooks and articles. In order to limit the scope of the research, a number of assumptions were made. Conflicting viewpoints underlying certain of these assumptions were discussed. Some of the important conclusions reached are that the provisions of the Vienna Convention on the Law of Treaties should be taken into account when interpreting South African legislation (including Double Tax Agreements), and that the Organisation for Economic Cooperation and Development (OECD) Commentary may be relied upon when interpreting OECD based Double Tax Agreements in South Africa. No conclusion was reached on whether to apply an ambulatory or a static basis of interpreting the OECD Commentary, however. The final conclusion of the research is that the services rendered in South Africa on a recurrent basis would be geographically and commercially coherent and consequently meet the "location test'. It is clear that as the services are rendered regularly and recurrently, they would be regarded as having the necessary permanence and would meet the 'duration test'. The place of business would therefore be regarded as being fixed (having the necessary degree of permanence). As the services would be rendered at the place of business of the South African entity, they would be regarded as being rendered 'through' the place of business and the foreign entity would be regarded as having a permanent establishment in South Africa (as defined in Article 5(1) of the OECD Model Tax Convention}. The South African Government would therefore be entitled to tax the income attributable to the permanent establishment and the income earned by the non resident employees, who rendered services in South Africa for the permanent establishment. Once the entitlement to tax exists, South African legislative rules determine how South Africa proceeds to tax the income.
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Bruzková, Nela. "Zaměstnanecké vztahy se zahraničním prvkem." Master's thesis, Vysoká škola ekonomická v Praze, 2014. http://www.nusl.cz/ntk/nusl-264221.
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The Master s thesis presents and summarizes problematic areas of the Czech legislation related to the occupational relations with a foreign subject. Essential literature used for this purpose were Employment of foreigners and sending employees and self-employed abroad. 2nd update. ed. written by P. Boušková and International employment, posting and hiring workers, 1st edition, written by L. Rytířová and J. Teperové. However it was necessary to draw on bilateral agreements and legislation, both Czech and international. The content has been structured into five main chapters, the first one is devoted to the legal regulation of occupational relations with a foreign subject, the second chapter contains analysis of labor migration and its problems. The third and fourth delineated a structure of employment and social security. Final chapter is devoted to the migration of Czech citizens abroad. The various major chapters have been divided into subchapters which followed the different parts of the main topic in detail.
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Monsenego, Jérôme. "Taxation of foreign business income within the European internal market : an analysis of the conflict between the objective of achievement of the European internal market and." Doctoral thesis, Handelshögskolan i Stockholm, Institutionen för Juridik, språk och ekonomisk statistik, 2011. http://urn.kb.se/resolve?urn=urn:nbn:se:hhs:diva-1287.
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Member States' rules on the taxation of the foreign business income of companies, whether they are based on the fiscal principle of territoriality or on the principle of worldwide taxation, raise complex issues of compatibility with the law of the European Union. Areas of conflict include particularly the taxation of foreign profits, the deduction of foreign losses, the elimination of international double taxation, and the attribution of profits to permanent establishments. The dissertation analyses these conflicts on the basis of a study of the case law of the European Court of Justice. Although this analysis provides some guidance for the taxation of companies when they carry out business activities throughout the European Union, it is concluded that the Court cannot, by itself: solve the conflict between the taxation of business income in a cross-border context and the objective of achievement of the internal market.Diss. Stockholm : Handelshögskolan i Stockholm, 2011
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Jaradat, Ruba. "The impact of donor and recipient government policies and practices on the effectiveness of foreign aid to a middle income developing country : case studies from Jordan." Thesis, University of Huddersfield, 2008. http://eprints.hud.ac.uk/id/eprint/2975/.
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This research investigates the foreign aid policies and practices of donor countries and of Jordan, a middle-income aid recipient country, through an examination of case studies of recent aid provision to Jordan. It examines the bearing of these policies on the effectiveness and efficiency of aid projects. The research concentrated on four case studies carefully chosen by the criteria of different donor nations and policies; and the different nature of the projects that cover the four main areas of development needs for Jordan. The case studies consisted of analysis of documentation and outcomes, and significant interviews with the selected participants. The case studies were chosen to explore the different mission statements, policies and practices and included the GTZ- funded Petra Stone Preservation Project, the USAIDfunded ICT Initiative, the DFID-funded Capacity Building in the Management of Jordan’s Education Services Project, and the JICA-funded Improvement of Water Supply System to Greater Amman Project. The study examines the effectiveness of aid in poor policy environments. It shows that the role of donors in ensuring the effectiveness of the aid they present goes beyond selecting recipients based on their policies and governance. Indeed, foreign aid is not donor-neutral and its effectiveness is not only dependent on the quality of governance and institutions of the recipients. The research demonstrates that a donor’s national interests and the influence of stakeholders determine the course and benefits of aid, and that judgements of success or failure vary between the standpoints of the donor and the recipient. The study investigates the impact of a number of variables on the effectiveness of foreign aid. Those variables include aid project design and delivery mechanisms, and institutional capacity and cultural constraints of aid recipients. The research focuses on relationships between donors and recipients and the differences in interests and objectives. It also looks at the impact of conditionality and tied aid on the sustainable benefits of the aid intervention. ii Although existing literature does address some of these considerations, there is very little direct evidence which links development theory with detailed practical examples. Where such examples are available, they are invariably weighted heavily by evidence which originates with, and is interpreted through, donor perceptions. This study provides a balanced analysis of four initiatives taking account of both donor and recipient expectations, experiences and assessments.
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He, You-Fin. "The concept of controlled foreign company and its complience with the EU-law : Does the Swedish chapter 39a Income Tax Act constitute a breach on freedom of establishment?" Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Rättsvetenskap, 2011. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-15553.
Full textAbstract:
Establishment in foreign countries can be achieved through a subsidiary company or a permanent establishment. Profit of a subsidiary company is normally taxed in accordance with the law of the country of where it is established, since a subsidiary company constitutes a separate legal entity. A permanent establishment on the other hand is not a separate legal entity, therefore profit in a permanent establishment is usually added on to the company’s total profit and taxed in accordance with the law of the country of where the company is established. Establishing business activities in foreign countries do normally not create problems, unless the business is carried on in a low tax jurisdiction. If that is the case, unlimited opportunities are created for companies to circumvent domestic taxation by transferring profit to the low tax jurisdiction, which in turn decreases the domestic tax base. In Sweden this kind of circumvention is precluded by chapter 39a ITA, in the meaning that a shareholder in a foreign company can be tax liable of low taxed profit in a foreign. The question that arises is whether chapter 39a ITA infringes on freedom of establishment. The outcome in the analysis is that there is a likeliness that chapter 39a ITA constitutes a restriction on the freedom of establishment. The escape provided in article 52 TFEU cannot justify the measure. Nor is it likely that the measure can be justified by the rule of reason. In the light of the assessment done in the analysis, it can be concluded that the chapter 39a ITA is applied in a non-discriminatory manner, satisfies a mandatory requirement (prevention of tax avoidance) and is regarded as appropriate in securing the achievement of the objectives. But there is a potential risk that measure will fail in the proportionality test.
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Esscher, Annika. "Maternal Mortality in Sweden : Classification, Country of Birth, and Quality of Care." Doctoral thesis, Uppsala universitet, Internationell mödra- och barnhälsovård (IMCH), 2014. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-216781.
Full textAbstract:
After decades of decrease, maternal mortality rates have shown a slight increase in Europe. Immigrants, especially Africans, have shown to be at higher risk than native women. This could not be explained solely by well-known obstetric and socio-economic risk factors. The aim of this thesis was to study incidence, classification and quality of care of maternal deaths in Sweden, with focus on the foreign-born population. The study population was identified through linkage of the Cause of Death Register, Medical Birth Register, and National Patient Register, and medical records obtained from hospitals. Data from registers, death certificates, and medical records were reviewed. Suboptimal care was studied by structured implicit review of medical records. Differences between foreign- and Swedish-born women were analysed by relative risks, Chi2- and Fisher’s exact test. Underreporting of maternal mortality was shown to be substantial: as compared to the official statistics, 64% more maternal deaths were identified. Women born in low-income countries were identified as being at highest risk of dying during reproductive age in Sweden. The relative risk of dying from diseases related to pregnancy was 6.6 (95% confidence interval 2.6–16.5) for women born in low-income countries, as compared to Swedish-born women. Major and minor suboptimal factors related to care-seeking, accessibility, and quality of care were found to be associated with a majority of maternal deaths and significantly more often to foreign-born women. Suboptimal factors identified included non-compliance, communication barriers, and inadequate care. The rate of suicides during pregnancy or within one year after delivery did not change during the last three decades, and was higher for foreign-born women. A majority of women who committed suicide had been under psychiatric care, but such documentation at antenatal care was inconsistent, and planning for follow-up postpartum was generally lacking. The conclusion of this thesis is that foreign-born women are a high-risk group for maternal death and morbidity that calls for clinical awareness with respect to their somatic and psychiatric history, care-seeking behaviour, and communication barriers. Cross-disciplinary care is necessary, both in obstetric emergencies and in cases of maternal psychiatric illness, to avert maternal death and suicide.
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Krčmová, Michaela. "Dopady ATAD na zdaňování příjmů zahraničních společností ovládaných daňovým rezidentem ČR." Master's thesis, Vysoké učení technické v Brně. Fakulta podnikatelská, 2020. http://www.nusl.cz/ntk/nusl-417407.
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This diploma thesis deals with the impact of the ATAD on the taxation of income of foreign companies controlled by a Czech resident – a legal entity. It describes, analyzes and systematizes the current legal situation and changes introduced into the area by the implementation of rules for controlled foreign companies into domestic legislation. This thesis includes a draft of the methodology for the application of rules from the perspective of the Czech corporate income taxpayer.
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Sene, Seydina Ousmane. "FOOD IMPORTS UNDER FOREIGN EXCHANGE CONSTRAINTS IN THE CFA’S FRANC ZONE OF SUB-SAHARAN AFRICA (SSA)." UKnowledge, 2014. http://uknowledge.uky.edu/agecon_etds/26.
Full textAbstract:
To respond to the high imported food prices in their domestic markets, net food importing countries in the Communauté Financière Africaine (CFA) zone[1] are adjusting their import tariffs and homologate domestic prices of imported commodities such as rice, wheat, maize, and sugar. This research uses a multivariate specification of error correction model (VECM) of estimation to investigate the link between food imports, world price index of rice, wheat, maize and sugar, real effective exchange rates, domestic food production, GDP, and trade openness in the short and long run. The data are on each homogenous commodity from 1969 to 2012. This research finds a long-run relationship between world price index, domestic production, GDP, real effective exchange rates and trade openness. Under fixed exchange rates regime, GDP, domestic food production, world price index of food, and trade openness are the determinants of food imported in the CFA zones. Policy options focusing on long-term investment in domestic food production of rice, wheat, maize and sugar, and trade openness are the fundamental factors to curtail the increasing food import volume/bill under fixed exchange rate regime in the CFA zones.
[1] The CFA zone in Sub-Saharan Africa is the WAEMU and CEMAC Countries, which are listed and represented in figure 1.
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Bellak, Christian, Markus Leibrecht, and Roman Römisch. "New evidence on the tax burden of MNC activities in Central- and East-European new member states." SFB International Tax Coordination, WU Vienna University of Economics and Business, 2005. http://epub.wu.ac.at/1120/1/document.pdf.
Full textAbstract:
Company-taxation policies in the Central and East European New Member States (CEE-NMS) have been frequently characterised as tax-cutting strategies in order to attract Foreign Direct Investment (FDI). On the basis of a survey of six empirical studies a median value of the tax-rate elasticities of FDI of -0.22 in CEE-NMS and mediterranean periphery countries is derived. Yet, these tax-rate elasticities probably suffer from a sort of measurement error bias since these studies entirely rely on the host country Statutory tax rate as measure of tax burden. Building on a thorough criticism of FDI as a measure reflecting multinational activity and the Statutory tax rate as a reliable measure of the effective tax burden, 315 effective average bilateral tax rates (BEATR) are calculated for seven home countries and five CEE-NMS for the period 1996-2004, following the approach of Devereux and Griffith (1998). Since our empirical results show substantial differences in the variability of the host country Statutory tax rates and the BEATRs, it is contended that the latter should be used as explanatory variables in empirical studies.Series: Discussion Papers SFB International Tax Coordination