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Dissertations / Theses on the topic 'Income tax avoidance law'

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Published: 4 June 2021

Last updated: 1 February 2022

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1

Tarrant, Greg. "The distinction between tax evasion, tax avoidance and tax planning." Thesis, Rhodes University, 2008. http://hdl.handle.net/10962/d1004549.

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Tax avoidance has been the subject of intense scrutiny lately by both the South African Revenue Service ("the SARS") and the media. This attention stems largely from the recent withdrawal of section 103(1) together with the introduction of section 80A to 80L of the South African Income Tax Act. However, this attention is not limited to South Africa. Revenue authorities worldwide have focused on the task of challenging tax avoidance. The approach of the SARS to tackling tax avoidance has been multi-faceted. In the Discussion Paper on Tax Avoidance and Section 103 (1) of the South African Income

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2

Stopforth, David Paul. "A history of the anti-avoidance legislation applying to settlements for income tax purposes." Thesis, University of Glasgow, 1988. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.254093.

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3

Haffejee, Yaasir. "A critical analysis of South Africa's general anti avoidance provisions in income tax legislation." Thesis, Nelson Mandela Metropolitan University, 2009. http://hdl.handle.net/10948/1243.

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This treatise was undertaken to critically analyse the new general anti avoidance rules (new GAAR) as set out in sections 80A to 80L of the Income Tax Act1. A discussion on the difference between tax evasion and tax avoidance was performed in the first chapter. The goals of this treatise were then set out. An analysis of the requirements for the application of the new GAAR was performed in the second chapter. The courts have historically reviewed the circumstances surrounding an arrangement when determining whether tax avoidance has occurred. The new GAAR requires the individual steps of an ar

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4

Prebble, Zoë, and John Prebble. "Comparing the General Anti-Avoidance Rule of Income Tax Law with the Civil Law Doctrine of Abuse of Law (Part I)." IUS ET VERITAS, 2016. http://repositorio.pucp.edu.pe/index/handle/123456789/123574.

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This paper compares the general anti-avoidance rule of incometax law with the Civil Law doctrine of abuse of law (Rechtsmissbrauch, abusde droit) in eight jurisdictions: Germany, Croatia, New Zealand, Australia, France, the e uropean u nion, the u nited s tates and the United Kingdom. The paper addresses the statutory and judge-made general anti-avoidance rules in these jurisdictions and deals with the core concept of avoidance an on how these eight jurisdictions either frustrate avoidance or allow it.<br>Este artículo compara la norma anti-elusiva general de la ley del impuesto a la renta con

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5

Kujinga, Benjamin Tanyaradwa. "A Comparative Analysis of the Efficacy of the General Anti-Avoidance Rule as a Measure Against Impermissible Income Tax Avoidance in South Africa." Thesis, University of Pretoria, 2013. http://hdl.handle.net/2263/33430.

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This thesis comparatively analyses the SA income tax general anti-avoidance rule (GAAR) in s 80A-L of the Income Tax Act 58/1962 and similar rules in Australia, Canada, the UK and the judicial doctrines in the US and the UK. It is argued that, while the SA GAAR may serve as a deterrent, it is going to have limited efficacy against impermissible tax avoidance due to the uncertainty it creates. It is argued that uncertainty will cause judicial activism to protect permissible tax avoidance, extensive and inconsistent judicial interpretation and confusion amongst taxpayers and SARS as to what cons

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6

Prebble, Zoë, and John Prebble. "Comparing the General Anti-avoidance Rule of Income Tax Law with the Civil Law Doctrine of Abuse of Law (Part II)." IUS ET VERITAS, 2016. http://repositorio.pucp.edu.pe/index/handle/123456789/123114.

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This article compares and analyzes how member States of the European Union, the United States of America and the United Kingdom combat tax avoidance through its legal systems. The article addresses issues such as the influence of the Court of Justice of the European Union and the case Cadbury Schweppes in establishing anti-avoidance rules in member States of the European Union and the application of Business Purpose Doctrine in the United States of America and the United Kingdom.<br>El presente artículo compara y analiza la manera en que los Estados miembros de la Unión Europea, los Estados Un

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7

Loof, Grethe. "A critical analysis of the requirements of the South African General Anti Avoidance Rule Section 80A of the Income Tax Act 58 of 1962." Thesis, University of Cape Town, 2013. http://hdl.handle.net/11427/4655.

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Includes bibliographical references.<br>I welcome you in reading this research dissertation looking at the South African General Anti Avoidance Rule. I hope that this paper will shed some light on the complex requirements of the GAAR as contained in section 80A, read together with relevant sections.

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8

Tooma, Rachel Anne Law Faculty of Law UNSW. "A case for a uniform statutory general anti-avoidance rule in Australian taxation legislation." Awarded by:University of New South Wales. School of Law, 2007. http://handle.unsw.edu.au/1959.4/29348.

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Taxpayer certainty is the most frequently cited argument against statutory General Anti-Avoidance Rules (GAARs). However the vast literature criticising statutory GAARs fails to consider the extent of taxpayer uncertainty, and the potential for taxpayer uncertainty, in jurisdictions without a statutory GAAR. This thesis examines that gap in the literature. The thesis uses inductive reasoning to suggest that there is greater taxpayer certainty where a statutory GAAR exists and is appropriately administered. Specifically, it uses a case study to demonstrate that there is greater uncertainty

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9

Ogula, Diana Khabale. "An analysis of the judicial approach to the interpretation of tax avoidance legislation in South Africa." Thesis, Nelson Mandela Metropolitan University, 2012. http://hdl.handle.net/10948/d1012093.

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Tax evasion and avoidance costs South Africa billions of rand each year. This treatise examines the judiciary’s view and/or attitude to the dividing line between legitimate and illegitimate tax avoidance. It seeks to find out how South African courts have ultimately dealt with the old GAAR section 103(1). The treatise seeks to establish the role that the judiciary plays in tax avoidance and whether it has been pro-fiscus or pro-taxpayer in its deliberations of tax avoidance cases. The treatise focuses specifically on the judicial responses to the General Anti-avoidance Rule Section 103 of the

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10

Weston, Tracey Lee. "A comparison of the effectiveness of the judicial doctrine of "substance over form" with legislated measures in combatting tax avoidance." Thesis, Rhodes University, 2004. http://hdl.handle.net/10962/100.

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Taxation statutes often provide opportunities for tax avoidance by taxpayers who exploit the provisions of the taxing statute to reduce the tax that they are legally required to pay. It is, however, important to distinguish between the concepts of tax avoidance and tax evasion. The central issue, especially where the contract has no business purpose, is whether it is possible for the substance and legal form of the transaction to differ to such an extent that a court of law will favour the substance rather than the legal format. The debate is whether the courts should be encouraged to continue

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11

Massaga, Salome. "The general anti-avoidance section: a comparative analysis of Section 80a of the South African Tncome Tax Act no. 58 of 1962 and Section 35 of the Tanzanian Income Tax Act no. 11 of 2004." Master's thesis, University of Cape Town, 2015. http://hdl.handle.net/11427/15177.

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The study will be based on a comparative analysis of the general antiavoidance section of the South African Income Tax Act no. 58 of 1962 and the Tanzanian Income Tax Act no. 11 of 2004. The focus is on how the two provisions are interpreted by showing the similarities and differences. The approach will be analytical and comparative, starting by showing the concept of tax avoidance and historical backgrounds of the two provisions.

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12

Sykes, Justin. "The Trouble With Transfer Pricing, and How to Fix It." Scholarship @ Claremont, 2014. http://scholarship.claremont.edu/cmc_theses/963.

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Many multinational firms, notably Apple Inc., have engaged in increasingly aggressive tax planning strategies which shift billions of dollars overseas. This paper examines the problem through a case study of Apple, concluding that while many loopholes are utilized, aggressive transfer pricing of intangible assets is the root of the problem. Several solutions are examined before concluding that the best solution is a partial elimination of deferral in the form of a minimum payout share.

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13

Olson, William H. (William Halver). "An Empirical Investigation of the Factors Considered by the Tax Court in Determining Principal Purpose Under Internal Revenue Code Section 269." Thesis, North Texas State University, 1987. https://digital.library.unt.edu/ark:/67531/metadc332329/.

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The purpose of this study was an empirical investigation of the factors considered by the United States Tax Court in determining whether the principal purpose for an acquisition was tax avoidance (or alternatively, given the totality of the surrounding circumstances, whether there was an overriding business purpose for the acquisition).

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14

Villagra, Cayamana Renée Antonieta, and del Pino Fernando Enrique Zuzunaga. "Trends in corporative income taxation in Latin America." Pontificia Universidad Católica del Perú, 2015. http://repositorio.pucp.edu.pe/index/handle/123456789/116131.

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The main objective of this study is to expose the corporative income taxation granted by the legislations of different Latin American countries, trying to identify and analyze trends that emerge from such treatment. This paper does not intend to make a critical or comprehensive analysis of the corporative income taxation. This paper identifies the most important issues of the resident’s income taxation, deductible expenses, non-resident taxation and withholdings, and the anti-avoidance measures introduced by the domestic legislation of Latin American countries in order to avoid the base er

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15

Okuma, Alessandra de Souza. "Normas anti-elusivas domésticas e internacionais no direito tributário internacional." Pontifícia Universidade Católica de São Paulo, 2009. https://tede2.pucsp.br/handle/handle/8826.

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Made available in DSpace on 2016-04-26T20:29:54Z (GMT). No. of bitstreams: 1 Alessandra de Souza Okuma.pdf: 2067533 bytes, checksum: fb2d17d87e735a3f03a1c33e12624ab6 (MD5) Previous issue date: 2009-10-09<br>The purpose of this paper is the analysis of anti-avoidance rules in the Brazilian law, as well as these provided by international treaties executed by Brasil, regarding the corporate income tax. Our opinion on the extension of the general anti-avoidance provision contained in domestic law is based on the following premises: (i) the theory of autopoietic systems by Niklas Luhmann; (ii) ta

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16

Tori, Vargas Fernando, and Alzza Efraín Rodríguez. "Alcances de la Norma Anti- Elusiva Específica Aplicable a la Reorganización de Sociedades." Derecho & Sociedad, 2015. http://repositorio.pucp.edu.pe/index/handle/123456789/117020.

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This paper analyses national and international background of the anti-avoidance rule described in article 105-A of such law, its scope and its relationship with corporate reorganizations’ Peruvian income tax regime. In addition, the article will cover the discussion on the relationship between general anti-avoidance rule and specific anti-avoidance rules.<br>El presente trabajo analiza los antecedentes nacionales e internacionales de la norma anti-elusiva vigente, prevista en el artículo 105-A de la referida Ley, su alcance y su relación con el régimen tributario aplicable a las reorganizacion

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17

Masters, Colin David. "The avoidance of tax on income, profits and gains." Thesis, University of Southampton, 1990. https://eprints.soton.ac.uk/349251/.

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This thesis deals with the various ways taxpayers have employed to avoid paying tax on income, profits and gains and the responses of the judges and legislators. Each type of avoidance is followed from its first appearance to the present day, where appropriate. The respective manoeuvres of the taxpayers, on the one hand, and the Legislature, on the other, are chartered, as is the attitude of the courts. There are four sections. In the first, the various categories of tax avoidance arrangements that have been implemented over the years in the United Kingdom are examined. The second is concerned

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18

Lee, Soojin. "News Media Coverage of Corporate Tax Avoidance and Corporate Tax Reporting." WU Vienna University of Economics and Business, Universität Wien, 2015. http://epub.wu.ac.at/4541/1/SSRN%2Did2603344.pdf.

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Drawing upon media agenda-setting theory and previous studies in organizational impression management, this paper empirically investigates the influence of tax avoidance news on corporate tax reporting. This study is based on the pronounced discontinuity in the amount of news articles related to tax avoidance in the United Kingdom over two periods (2010-2011 and 2012-2013). A difference-in-differences design is employed in order to enable a comparison of the media effects on those firms that have been reported in tax avoidance news versus those without media attention. Using a sample of annual

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19

Marais, Albertus Johannes. "Simulation discussed : tax avoidance in the common law." Master's thesis, University of Cape Town, 2012. http://hdl.handle.net/11427/10897.

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Includes bibliographical references.<br>The simulation doctrine has, in the law of taxation, always played the role of being SARS' remedy in the common law, vis-a-vis its legislated cohorts, viz. both the specific and general anti-avoidance provisions contained in the various tax statutes. Building on the principles established in Zandberg v Van Zyl, Dadoo Ltd and others v Krugersdorp Municipal Council and Commissioner of Customs and Excise v Randles Brothers & Hudson Ltd, the test which emerged and has been applied since, is broadly recognised as being that as formulated by Watermeyer JA in R

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20

Perry, Nina. "Expenditure in South African Income Tax law." Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/4536.

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21

Theron, Lee. "The use of corporate structures and tax avoidance." Master's thesis, University of Cape Town, 2015. http://hdl.handle.net/11427/16729.

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Includes bibliographical references<br>South Africa has seen many developments in both the areas of corporate law and tax legislation. The legislation in question has developed from an apartheid or pre-democratic era to that of the current democratic South Africa, in which individuals have the freedom to become entrepreneurs, and have the opportunity to start up small to medium and larger enterprises, in order to firstly make a profit but also to ensure that they enjoy the benefits which the separate legal personality of Corporate Structures are entitled to. The focus of the research was to ca

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22

Wilson, Peter Antony. "'BRICS' and international tax law." Thesis, Queen Mary, University of London, 2017. http://qmro.qmul.ac.uk/xmlui/handle/123456789/24872.

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This Thesis studies a new and evolving area of international tax law, namely, the international tax law of Brazil, Russia, India, China and South Africa, the 'BRICS', and concludes that the thrust of their divergences from the developed world's international tax law evolves from the necessity to counter the significant illicit outflow of funds while not disturbing inbound FDI or, in recent times, their outbound FDI while ensuring profits are taxed where created. The design of the divergences reflects more on the initial limited manpower capacity of their emerging tax authorities to deal with t

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23

Krušinová, Marie. "Mzdové účetnictví." Master's thesis, Vysoká škola ekonomická v Praze, 2011. http://www.nusl.cz/ntk/nusl-151513.

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Diploma thesis deals with the issue of payroll accounting. The teoretical part consists of descriptions of separate systems conected with the main theme as law system, system of personal income tax, system of health insurance, social insurance and accounting. The teoretica part is completed also from the international point of view. In the end of the thesis all system and principles are connected by examples in the practial part.

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24

Lord, Tristan Sacha. "Transfer Pricing in South African income tax law." Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/4656.

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'Transfer pricing continues to be, and will remain, the most important international tax issue facing MNEs.' The term 'transfer pricing' is used to describe arrangements involving the transfer of goods or services, at an artificial price, in order to transfer income or expenses from one enterprise to an associated enterprise in a different tax jurisdiction. This results in the income derived at for each enterprise being disproportionate to their relative economic contributions, and thus impacting the relevant tax jurisdictions' fair share of tax. Tax authorities are therefore focusing their at

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25

Vella, John. "Avoidance, characterisation and interpretation in tax, corporate and financial law." Thesis, University of Cambridge, 2007. https://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.707899.

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26

Benn, Dean John. "Tax avoidance in South Africa: an analysis of general anti-avoidance rules in terms of the Income Tax Act 58 of 1962, as amended." Bachelor's thesis, University of Cape Town, 2013. http://hdl.handle.net/11427/4565.

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27

Kanyenze, Rumbidzai. "An analysis of the income tax consequences resulting from implementing the Income Tax Bill (2012) in Zimbabwe." Thesis, Rhodes University, 2015. http://hdl.handle.net/10962/d1017536.

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The Income Tax Bill (2012) proposes certain changes to the existing Income Tax Act that will impact on the method used to determine the taxable income of a taxpayer in Zimbabwe. Therefore, it is important to understand the tax consequences the Income Tax Bill creates for the taxpayer. The research aimed to elaborate on and explain the tax consequences that will arise as a result of applying the Income Tax Bill in Zimbabwe. The research was based on a qualitative method which involved the analysis and the interpretation of extracts from legislation and articles written on the proposed changes.

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28

Griffin, Nicholas. "The development of the simulated transactions doctrine as means of combating impermissible tax avoidance." Master's thesis, Faculty of Law, 2021. http://hdl.handle.net/11427/32694.

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Tax avoidance may be an inevitable consequence of taxation; however, it remains a great drain on the fiscus. There are many ways in which the Commissioner may attack avoidance arrangements in order to lessen the drain on the fiscus. One manner in which the Commissioner may attack avoidance arrangements is through the doctrine of simulated transactions. Given that the simulated transactions doctrine is ordinarily a contract law doctrine and not strictly speaking a tax law mechanism one might wonder how this area of law might develop into an antiavoidance mechanism. This contribution sought to u

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Grewal, Rajbir Singh. "Towards integrity in tax law : the problem of form and substance in Canadian tax jurisprudence." Thesis, University of British Columbia, 2008. http://hdl.handle.net/2429/4076.

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This study examines the problem of form and substance in Canadian tax jurisprudence, which has been characterized by a troubling equivocation between formalistic and substantive approaches in cases involving tax avoidance transactions with the current period of jurisprudence dominated by formalism. The vacillation of Canadian jurisprudence contrasts with the consistently substantive tax jurisprudence of the United States. The latter situation discloses an unresolved doctrinal tension in Canadian tax jurisprudence between two viable doctrinal alternatives. This study seeks to resolve the proble

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Grebe, Alta-Mari. "The income tax implications resulting from the introduction of section 12N of the Income Tax Act." Thesis, Nelson Mandela Metropolitan University, 2014. http://hdl.handle.net/10948/d1020787.

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Section 12N, introduction into the Income Tax Act by way of Taxation Laws Amendment Act and which became effective on 2 November 2010, provides for allowances on the leasehold improvements on government-owned land and land leased from certain tax exempt entities as stipulated in section 10 (1) (cA) and (t). As section 12N deems the lessee to be the owner of the leasehold improvement, the lessee now qualifies for capital allowances which were previously disallowed.

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31

Lekman, Daniela Adela. "Principal purpose tests of tax treaty law in comparison with the General Anti-Avoidance rule of the EU Anti-Tax Avoidance Directive." Thesis, Uppsala universitet, Juridiska institutionen, 2020. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-422870.

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32

Ellis, Jason Brian. "The implications for tax planning of the general anti-avoidance provisions : part IVA of the Income Tax Assessment Act /." Title page, table of contents and introduction only, 1993. http://web4.library.adelaide.edu.au/theses/09C/09ce471.pdf.

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33

Grobler, Daniel Jacques. "The "realisation company" concept in South African income tax law." Thesis, Nelson Mandela Metropolitan University, 2012. http://hdl.handle.net/10948/2118.

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The Supreme Court of Appeal has revisited the issue that has attracted the most litigation in South African tax law: whether gains from the disposal of an asset are of a capital or of a revenue nature. In CSARS V Founders Hill (509/10) [2011] ZASCA 66, 73 SATC 183 the court held that „intention‟ is not conclusive in the enquiry and cannot be the litmus test in determining the nature of proceeds from the sale of an asset. This judgement relegates intention to only one of the factors to be considered as it was held that it should be considered objectively whether the taxpayer is actually trading

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34

Polizelli, Victor Borges. "O princípio da realização da renda e sua aplicação no imposto de renda de pessoas jurídicas." Universidade de São Paulo, 2009. http://www.teses.usp.br/teses/disponiveis/2/2133/tde-18112011-145517/.

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No contexto do sistema tributário nacional brasileiro, uma apuração correta da renda tributável demanda o respeito a princípios abrigados pela Constituição Federal expressa ou implicitamente e, dentre estes, vale citar o princípio da realização da renda que, numa descrição simplificada, auxilia na detecção da capacidade econômica apta a sofrer tributação, uma vez que delineia diretrizes mais concretas para a identificação do momento adequado para que tal tributação se implemente. Este estudo enfoca o momento temporal em que se consideram ocorridos os fatos econômicos individuais que se ajuntam

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Stroope, John C. (John Clarence). "Income Tax Evasion and the Effectiveness of Tax Compliance Legislation, 1979-1982." Thesis, University of North Texas, 1988. https://digital.library.unt.edu/ark:/67531/metadc330580/.

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The federal income tax system in the United States depends upon a high degree of voluntary compliance. The IRS estimates that the voluntary compliance level is declining and that this tax compliance gap cost the government an estimated $90.5 billion in 1981. Between 1979 and 1982, Congress made several changes in the tax laws designed to improve tax compliance. Extensive data was collected by the IRS for 1979 and 1982 through the random sample audits of approximately 50,000 taxpayers on the Taxpayer Compliance Measurement Program (TCMP), which is conducted every three years. During the period

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Tarsitano, Alberto. "Illegitimate Tax Avoidance and Rule XVI of Preliminary Title of Tax Code." IUS ET VERITAS, 2014. http://repositorio.pucp.edu.pe/index/handle/123456789/123330.

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The author analyzes a very important issue such as illegitimate tax avoidance. He begins by explaining the content of the concept of illegitimate tax avoidance, and also he points out the differences with other concepts like tax evasion and tax planning. Then, he comments the debate on the use of legal figures which doesn’t belong to Tax Law, in order to solve issue of illegitimate tax avoidance. Finally, he explains the scope and the application of the Peruvian general anti-avoidance rule stipulated in the Peruvian Tax Code.<br>El autor analiza un tema de suma importancia como es el de la elu

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Cruceru, Luiza Brindusa. "Treaty shopping and the abuse of income tax conventions." Thesis, McGill University, 2005. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=83949.

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This study proposes to analyze the phenomenon of tax treaty abuse and the use of tax treaties as tools to avoid or minimize the taxation by residents doing business in a foreign jurisdiction. This study analyses a particular strategy using tax treaties known as "treaty shopping." This paper will argue that treaty shopping constitutes an abuse of the tax treaty regime. However, this study rejects the traditional arguments against treaty shopping and proposes a different basis to challenge the legitimacy of this practice and to explain why this strategy constitutes an improper use of tax

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Beckett, Neal Peter. "Combating abusive EU corporate income tax practices." Thesis, Brunel University, 2016. http://bura.brunel.ac.uk/handle/2438/13492.

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This thesis examines the concept of EU corporate tax abuse in light of the tensions between the protection of EU Fundamental rights and the susceptibility of those rights to abuse. Consideration is given to the major tax abuse practices and arrangements, accompanied by analyses of the responses of a selection of EU member states, and the role and impacts of judicial, state and commercial stakeholder interests. Consequent upon an examination of why past proposals have failed to attain either policy adoption or policy success, it is suggested that the legal concepts of abuse of rights, substance

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Fowler, Joshua Emmanuel. "The Trouble with Tax Avoidance: Two General Anti-Avoidance Rules, a Judicial Doctrine, and their Respective Implications for the value of Certainty in Tax Law." Thesis, University of Canterbury. School of Law, 2013. http://hdl.handle.net/10092/8358.

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Tax avoidance is an exceedingly complex area of law. It is also a matter generally found not far from the headlines, or from the concerns of state and policy forums such as the G8 and the OECD. In an increasingly capital mobile world, the concern on the part of Governments for the protection of their sources of revenue has increased. Adam Smith’s four canons of taxation are well known. In his work, The Wealth of Nations, Smith regarded the values of certainty, equity, efficiency and convenience as integral to the functioning of a tax system. Among these, however, Smith would seem to have reg

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40

Wang, Frederick. "Tax haven planning within the scope of the North American anti-avoidance legislation." Thesis, McGill University, 1986. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=63890.

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Govender, Preshnee. "Does a mineral right constitute 'immovable property' for purposes of the Income Tax Act and double tax treaties?" Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/9170.

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Includes bibliographical references.<br>This research paper analyses the income tax impact for international (non-resident) companies that dispose of their shares in mining or oil and gas companies situated in South Africa. Typically, a disposal of shares by a non-resident in a property-rich company in South Africa would attract CGT. In the case of the minerals sector, it is automatically assumed that a mining or oil and gas company is a so-called “land-rich” or “property-rich” company due to the nature of its operations. This paper seeks to test that assumption, ie do shares in a mining or oi

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Baker, Philip. "A comparative study of the tax treatment of international commercial transactions." Thesis, SOAS, University of London, 1985. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.337617.

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Correia, Miguel G. "Taxation of corporate groups under a corporation income tax : an interdisciplinary and comparative tax law analysis." Thesis, London School of Economics and Political Science (University of London), 2010. http://etheses.lse.ac.uk/2786/.

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Corporate groups are notoriously difficult to tax. At the moment it is not clear whether corporate groups should be approached as single taxable entities, or whether a separate tax existence should be attributed to corporate group members. The current ambiguity generates a substantial deadweight loss. This study determines what may be the best approach to tax corporate groups, once the perspectives of government and corporate groups are taken into account. The study adopts an interdisciplinary approach, whereby elements, such as market imperfections, the economic, legal and functional nature o

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Loutzenhiser, Glen. "Income splitting, settlements and avoidance : taxing the family on business profits." Thesis, University of Oxford, 2009. http://ora.ox.ac.uk/objects/uuid:059b8ed4-a3fb-42bf-970e-77718ff105c9.

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In a progressive income tax system with an individual tax unit, high-rate taxpayers have an incentive to split income with lower-rate family members to minimise the family’s total tax burden. This raises equity and neutrality concerns. Adopting a spousal tax unit limits the gains from income splitting, but the individual is the better choice on privacy, autonomy, equality, definitional, marriage neutrality and work incentive grounds. Once the individual is chosen as the income tax unit, the control model provides a strong policy basis for attributing both earned and unearned income to individu

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Loomer, Geoffrey T. "Reformulating corporate residence : a coherent response to international tax avoidance." Thesis, University of Oxford, 2011. http://ora.ox.ac.uk/objects/uuid:1f515456-3d87-4942-9600-b9cfe73c6662.

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This thesis analyzes the concept of corporate residence, with particular reference to the law in the UK and Canada. It explores why corporate residence is relevant in tax policy, how corporate residence is understood in law, and how revenue authorities respond to the use and alleged 'abuse' of residence rules. Part I argues that the residence of taxpayers generally (individual or corporate) remains a relevant factor in international tax design, that taxation of corporations on the basis of residence has some justification, but that there is a disjunction between meaningful residence-based taxa

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Cassiem, Rehana. "The taxation of income and expenditure of Trusts in South Africa - are they still viable estate planning tools?" Thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/12821.

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Includes bibliographical references.<br>This research paper will explore the taxation of the income and expenditure in today’s day and age. We will have an in - depth look into the mechanics of trusts, to ascertain whether they still have a role to fulfil in estate planning. Therefore the paper will first explore the background in trusts in Section A, Section B will deal with how trusts are tax and Section C will try and answer why trusts are still popular amidst the unfavourable changes in recent legislation.

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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 f

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Ketchemin, Eric P. "A comparative analysis of the concept of fiscal jurisdiction in income tax law." Master's thesis, University of Cape Town, 2002. http://hdl.handle.net/11427/11303.

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Bibliography: leaves 324-333.<br>The purpose of this dissertation is to analyse the definitional rules of fiscal jurisdiction as well as the tax consequences resulting from the application of these rules, as implemented in the national tax law of the chosen jurisdictions. In essence, there are two main rules, which give content to the chosen theory of fiscal jurisdiction, mainly source and residence. It is trite that globalisation of the world's economies poses certain problems for international tax policy. Companies and individuals are becoming more mobile and therefore are able to exploit ta

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Calvert, Teresa Michelle. "An analysis of the 2006 amendments to the General Anti-Avoidance Rules : a case law approach / T. Calvert." Thesis, North-West University, 2011. http://hdl.handle.net/10394/6280.

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Tax avoidance has been a concern to revenue authorities throughout the ages, and revenue authorities worldwide are engaged in a constant struggle to ensure taxpayer compliance while combating tax avoidance. South Africa is no exception to this struggle and the increasingly innovative ways in which taxpayers seek to minimise their tax burdens necessitate amendments in order to remain at the forefront of taxpayer compliance. In view of the above, the general anti-avoidance rules (GAAR) have been amended numerous times to address weaknesses. The most recent of these amendments are those of 1996 a

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Nkerebuka, Eliya John. "Trading stock : a critical analysis of the application of Section 1 of the Income Tax Act no 58 of 1962." Master's thesis, University of Cape Town, 2015. http://hdl.handle.net/11427/19790.

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The right to tax is traditionally based on connection to jurisdiction. Taxation is divided into international and domestic systems. An international tax system subjects its residents to tax on their income from all around the world while a domestic tax system subjects its residents to tax only on income arising out of a source within the borders of such a State. Under the international tax system, a State's right to tax firstly depends on whether the taxpayer deriving the said taxable income is a resident of that country or not. With respect to an entity or enterprise, its place of effective m

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