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1

Vega, Rengifo Beatriz de la. "Taxation on mining and hydrocarbon investments." Pontificia Universidad Católica del Perú, 2014. http://repositorio.pucp.edu.pe/index/handle/123456789/116765.

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This article comments the most important aspects of the tax treatment applicable to investments of mining and oil and gas industry. The document highlights the relevant tax topics of the general tax legislation(Income Tax Law) and the special legislation of both industries (General Mining Law and Hydrocarbons Organic Law).<br>Este artículo comenta los aspectos más relevantes del tratamiento tributario de las inversiones de la industria minera y de hidrocarburos, resaltando los puntos principales de la legislación tributaria general (Ley del Impuesto a la Renta) y sectorial (Ley General de Mine
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2

Rumble, Tony Law Faculty of Law UNSW. "Synthetic equity and franked debt: capital markets savings cures." Awarded by:University of New South Wales. School of Law, 1998. http://handle.unsw.edu.au/1959.4/17591.

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Micro-economic reform is a primary objective of modern Australian socio-economic policy. The key outcome targetted by this reform is increased efficiency, measured by a range of factors, including cost reduction, increased savings, and a more facilitative environment for business activity. These benefits are sought by the proponents of reform as part of a push to increase national prosperity, but concerns that social equity is undermined by it are expressed by opponents of that reform. The debate between efficiency and equity is raging in current Australian tax policy, a key site for micro-eco
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3

Kadikov, Artem. "International taxation of cross-border digital commerce." Thesis, University of Oxford, 2015. https://ora.ox.ac.uk/objects/uuid:ea6c6f2e-c65f-4fa5-945a-22eb71e12667.

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This thesis discusses jurisdiction to tax cross-border digital commerce. The primary objective is to consider the reasons for the erosion of jurisdictional links, or nexus, between countries and taxpayers' digital activities and evaluate possible solutions for addressing such nexus erosion. Whilst it is argued that digital commerce is impossible to ring-fence due to digital technologies transcending all industries, the main focus of this research is on automated business models as case studies for the broader tax issues applicable across the entire digital economy. Using cloud computing, onlin
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4

Mkhize, Vukani. "A critical analysis of the tax implications for small and micro businesses." Thesis, Nelson Mandela Metropolitan University, 2011. http://hdl.handle.net/10948/1338.

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The South African economy has seen an increase in small businesses since 1994. This increase has been caused by an increase in unemployment rate and government interventions to promote small businesses. The government has through the National Treasury introduced various tax legislations to simplify and facilitate the tax processes that small businesses have to comply with. The discussion contained in this treatise seeks to critically analyse the tax implications for small and micro businesses. One of the small business tax legislations, Small Business Corporations, is discussed in chapter 2. T
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5

Jovanovich, Juan Martʹin. "Customs valuation and transfer pricing : is it possible to harmonize customs and tax rules?" Thesis, McGill University, 2000. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=31165.

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There is an overlap between the transfer pricing concepts that apply under tax and under customs regimes. This thesis aims to demonstrate (i) that customs and tax laws often share common principles in respect of related-party transactions; (ii) that transfer pricing as agreed to under one discipline should be recognized under the other; (iii) that the OECD Transfer Pricing Guidelines constitute a body of rules that is appropriate to supplement the related party provisions of the GATT/WTO Valuation Code ("GVC"); and (iv) that such guidelines are generally in accordance with the provisions of th
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6

Nakayama, Kiyoshi. "Transfer pricing taxation : Canadian perspective and Japanese perspective." Thesis, University of British Columbia, 1987. http://hdl.handle.net/2429/26143.

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For the last decades, transfer pricing has been one of the most important issues for both tax authorities and multinational corporations. On the one hand, tax authorities, despite their counter-measures, have not been able to cope with international tax avoidance or evasion using transfer pricing by multinational corporations owing to the deficiency of tax systems and the inability of tax administrations and this has resulted in a huge revenue loss to the coffers of their countries. On the other hand, while multinational corporations have been using transfer pricing as vehicles to maximize t
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7

Nimpongsak, Rachadapon. "Thai petroleum concession contract proposal for revision /." Thesis, Available from the University of Aberdeen Library and Historic Collections Digital Resources. Restricted: no access until March 27, 2014, 2009. http://digitool.abdn.ac.uk:80/webclient/DeliveryManager?application=DIGITOOL-3&owner=resourcediscovery&custom_att_2=simple_viewer&pid=25981.

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8

Kruger, Leander. "Comparison of taxation reforms regarding retirement funding between South Africa and the United Kingdom." Thesis, Nelson Mandela Metropolitan University, 2017. http://hdl.handle.net/10948/18200.

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The purpose of this study was to review the provision of public and private retirement funding in both South Africa and the United Kingdom and the role of taxation in encouraging greater private provision for retirement. The study described the basis of taxation and determination of ‘taxable income’ in each jurisdiction, before addressing the relationship between taxation and retirement funding in each jurisdiction respectively. Both jurisdictions have introduced significant reforms of their systems of retirement funding and these reforms were accordingly addressed in the present research. The
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9

Rahman, Kazi Muinur. "A proposal for the taxation of electronic commerce /." Thesis, McGill University, 2005. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=82668.

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The current international tax regime was conceived at the beginning of the 20th Century and the rules have remained relatively unchanged since then. The operational rules of the international tax regime were designed for an economic era in which major international commercial enterprises were confined within a physical paradigm, and they had succeeded in achieving an acceptable and practical allocation of tax revenue that was being generated from international commerce. As commerce sunders itself from its physical boundaries, the traditional international tax rules that are confined wit
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10

HERNÁNDEZ, GUERRERO Vanesa. "Tax incentives under the initiatives against harmful tax competition, the EC treaty provisions on state aid and the WTO Agreement on subsidies." Doctoral thesis, European University Institute, 2007. http://hdl.handle.net/1814/25400.

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Defence date: 17 December 2007<br>Examining Board: Prof. Ernst-Ulrich Petersmann (EUI Supervisor) ; Prof. Adolfo J. Martín Jiménez (Universidad de Cádiz, External Supervisor) ; Prof. Pierre-Marie Dupuy, EUI ; Mr. Richard Lyal, EC Commission<br>PDF of thesis uploaded from the Library digital archive of EUI PhD theses
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11

Hadida, Jonathan. "Prospects for multilateral cooperation in taxation." Thesis, McGill University, 2006. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=101818.

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Globalization has placed a considerable strain on the current international tax structure predicated upon bilateral tax treaties. Multilateral cooperation may allow nation states to overcome many of globalization's effects.<br>The two prospects for multilateral cooperation are the creation of an international tax organization and a multilateral tax treaty to replace the current bilateral tax treaty network. Whereas there is currently no organization responsible for the surveillance of the international tax system, such an organization is within the realm of possibility. The perfect home for su
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12

Birch, Charles 1971. "Evaluating mining and petroleum joint ventures in Australia : a revenue law perspective." Monash University, Faculty of Law, 2001. http://arrow.monash.edu.au/hdl/1959.1/8960.

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13

Abdelarahim, Abdelarahim Mohamed. "Libya's production sharing agreement in comparison with Iran's buyback contract." Thesis, University of Aberdeen, 2016. http://digitool.abdn.ac.uk:80/webclient/DeliveryManager?pid=229380.

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14

Stephens, Thomas Kojo. "Getting it right : the development of an effective regulatory and policy framework for the management of Ghana's upstream oil industry." Thesis, University of Aberdeen, 2014. http://digitool.abdn.ac.uk:80/webclient/DeliveryManager?pid=215548.

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Norwegian practice has largely permeated virtually every aspect of Ghana's oil industry. Extrapolation from Norway has been a step in the right direction as Norway is largely credited with adopting best industry practices in the management of its oil industry. Ghana's regulatory framework has evolved to resemble Norway's. Whilst not all this similarity is by design, that which is not has been reinforced by Norwegian practice. Norway's transparent and effective control of the industry by the Executive affords subordination of the industry's regulatory body to a powerful Ministry, which arrangem
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15

Rijntjes, Dick. "Does Hong Kong need tax treaties?" Thesis, Click to view the E-thesis via HKUTO, 1996. http://sunzi.lib.hku.hk/HKUTO/record/B3862784X.

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16

Massamba-Animbo, Stephane. "A comparison of the petroleum legislation of gabon and South Africa as instruments of development." Thesis, Nelson Mandela Metropolitan University, 2015. http://hdl.handle.net/10948/d1021143.

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The African continent is endowed with vast natural resources of minerals, such as cobalt, diamonds, gold, bauxite, iron, platinum, silver, uranium and mineral oil. Oil is unequally distributed in the continent, with some countries, such as Cameroon, Chad, Congo Brazzaville, Equatorial Guinea, Gabon and South Africa, being particularly well endowed. These natural resources can help accelerate development on the continent, especially in Gabon and South Africa if used strategically. This dissertation gives an overview of the international instruments, which play a key role in petroleum legislatio
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17

Burger, Bianca. "South African VAT implications in respect of supplies by non residents to residents." Thesis, Nelson Mandela Metropolitan University, 2014. http://hdl.handle.net/10948/d1019977.

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Paragraph 7(1) of the VAT Act provides for the charging of VAT at 14 percent on the supply of goods or services by a vendor in the course or furtherance of an ‘enterprise’, the importation into South Africa of goods by any person or the supply of ‘imported services’. The term ‘enterprise’ has been interpreted to require an on-going activity and therefore once off sales should be excluded. The sale must relate to enterprise activities, thereby excluding private sales. Furthermore the enterprise activities are required to be carried out in the Republic or partly in the Republic. Establishing whe
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18

Dema, Perisuo. "Structuring of reserve based finance for petroleum production in Nigeria : contractual, regulatory and tax issues." Thesis, University of Aberdeen, 2014. http://digitool.abdn.ac.uk:80/webclient/DeliveryManager?pid=214822.

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19

Segodi, Vusi Oscar. "A law regulating taxation of pension benefits in South Africa." Thesis, University of Limpopo, 2015. http://hdl.handle.net/10386/1435.

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Thesis (LLM. (Labour Law)) -- University of Limpopo, 2015<br>This mini-dissertation discusses the legal reform of the taxation of pension benefits under the South African law. This study also discusses how South African pension benefits are taxed in instances wherein the member exits the fund either as a result of resignation, death, dismissal, retrenchment, disability and retirement. It further discusses the comparative study between South Africa, Canada, Australia and United Kingdom
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20

Kerr, Evelina. "CFC legislation and its compliance with Community Law : Sweden's lack of double CFC tax relief." Thesis, Jönköping University, Jönköping University, Jönköping University, 2009. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-11041.

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<p>CFC legislation has become an instrument to protect national tax bases and minimize the abusive effects of international tax planning. The Swedish CFC legislation is found in chapter 39a of the ITA whereas it is established under what circumstances CFC taxation can arise. If a shareholder of a foreign legal entity is liable of CFC taxation in Sweden such a holder is also entitled to deduct tax paid by the CFC abroad. The purpose of the granted tax credit is to avoid double taxation, although if foreign tax is paid by another entity than the foreign entity in question such CFC-tax cannot be
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21

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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22

Poff, J. Kent. "An economic analysis of uniform capitalization of inventory costs under §263A of the Internal Revenue Code of 1986." Diss., Virginia Tech, 1991. http://hdl.handle.net/10919/37754.

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23

Chan, Kathryn. "Taxing charities, imposer les organismes de bienfaisance : harmonization and dissonance in Canadian charity law." Thesis, McGill University, 2006. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=99555.

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For many years, the determination of which organizations should qualify for the significant tax benefits accorded to "registered charities" ( "organismes de bienfaisance enregistres") under the Canadian Income Tax Act has been based, in all provinces, on the concept of charity developed by the English common law of charitable trusts. However, there are other sources of meaning for the concept of "charity" ( "bienfaisance") in Canada, including ancient, civil law sources that continue to form part of the basic law of Quebec.<br>This study challenges the longstanding, unijural approach to the re
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24

Al, Saedan Ahmad A. K. "The law governing oil concession agreements and the permanent sovereignty of states over their natural resources : with special reference to Islamic Shari'ah law." Phd thesis, Faculty of Law, 1992. http://hdl.handle.net/2123/8638.

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25

Osei-Hwere, Richmond. "Conflict of interest challenges facing Ghana's Petroleum Commission under the Petroleum Commission Act, 2011 (Act 821) proposals for reform." Thesis, University of Aberdeen, 2015. http://digitool.abdn.ac.uk:80/webclient/DeliveryManager?pid=228645.

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This thesis establishes the link between law, democratic governance and the institutional capacity needed for maximum control of hydrocarbon resources by the producer state, with the emphasis particularly on Ghana. The discoveries of hydrocarbon resources under the territorial waters and continental shelf of Ghana has set in motion a review of the pre-existing petroleum legislative framework in the country. The review is aimed at meeting the challenges of the nascent oil and gas industry taking into account modern trends adopted in the management of these resources. Prior to the discoveries, t
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26

Le, Roux Ayesha. "An analysis of the South African income tax legislation in respect of transfer pricing." Thesis, Nelson Mandela Metropolitan University, 2016. http://hdl.handle.net/10948/13105.

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Transfer pricing has become a very popular term in South Africa over the last few years, even more so since July 2013 when the Base Erosion and Profit Shifting (BEPS) Action plan was issued by the Organisation for Economic Co-operation and Development (OECD) and G20 (an international forum for the governments and central bank governors from 20 major economies). The OECD and G20 has issued the plan to address the perceived flaws in international tax rules, giving rise to profit shifting. Subsequently, the OECD has issued numerous reports and as a result has updated its 2010 Transfer Pricing Gui
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Üşenmez, Emre. "The UKCS fiscal regime : a proposal for reform." Thesis, University of Aberdeen, 2017. http://digitool.abdn.ac.uk:80/webclient/DeliveryManager?pid=233933.

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This interdisciplinary thesis combines economics and law disciplines in examining the current fiscal regime applicable to upstream petroleum activities in the UK with an overarching objective of developing a policy framework for a new fiscal regime that is not only stable enough to avoid future alterations but also sufficiently fair to balance the unaligned imperatives of the investors and the government. Since the initial days of hydrocarbon exploitation in the UK Continental Shelf the fiscal regime was subject to numerous changes in reaction to the dynamics of the time. Most of these changes
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Gutuza, Tracy. "An analysis of the methods used in the South African domestic legislation and in double taxation treaties entered into by South Africa for the elimination of international double taxation." Doctoral thesis, University of Cape Town, 2013. http://hdl.handle.net/11427/4628.

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Includes abstract<br>Includes bibliographical references.<br>This thesis adds to the body of literature exploring the policy principles of equity and neutrality, as applied in the context of methods relieving international double taxation and in the context of a recently opened and developing economy.
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Chiribagula, Nyumpa-Bashimba. "Vers une réforme du droit fiscal congolais: rationalisation du système d'imposition et de fiscalisation des activités économiques informelles :un impératif?" Doctoral thesis, Universite Libre de Bruxelles, 2003. http://hdl.handle.net/2013/ULB-DIPOT:oai:dipot.ulb.ac.be:2013/211311.

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Nikolakakis, Niki. "The international legal ramifications of the OECD's harmful tax competition crusade /." Thesis, McGill University, 2006. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=101823.

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In 1998 the Organization for Economic Cooperation and Development (the "OECD") commenced a campaign to eliminate harmful tax competition focusing on geographically mobile activities. The OECD targeted 35 jurisdictions and demanded that those nations amend their tax laws to remove the harmful features that provided more favorable tax treatment to geographically mobile capital than was available in some of its Member States. This thesis examines the international responsibility of the OECD and its Member States to determine whether their conduct in waging this campaign is in accordance with the
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31

Engelbrecht, Waldette Anne. "A critical analysis of the meaning of beneficial owner of dividend income received by a discretionary trust." Thesis, Stellenbosch : Stellenbosch University, 2013. http://hdl.handle.net/10019.1/85648.

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Thesis (MAccounting)--Stellenbosch University, 2013.<br>ENGLISH ABSTRACT: The term beneficial owner is most commonly found in the dividend, interest and the royalty articles of tax treaties (Baker, 2007:15), yet there is still uncertainty surrounding the actual meaning of the term (Du Toit, 2010: 500). Since Dividends Tax became effective in South Africa as from 1 April 2012, it has become necessary to clarify what the term beneficial owner means to correctly apply section 64E of the Income Tax Act No 58 of 1962 (‘Act’). Section 64EA(a) of the Act determines that the Dividends Tax liabil
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Lenik, Jean-Sébastien. "Prix de transfert & accords de repartition des couts (ARC)." Thesis, McGill University, 1999. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=30314.

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This thesis examines the transfer pricing issue within the perspective of setting up a cost contribution arrangement for the international management of intangible property.<br>To this end, the first part presents the general rules governing the transfer pricing area in Australia, Canada, France, and the United States. The provisions of these countries will serve as a guiding line of this study. The first part presents, as well, the OECD Transfer Pricing Principles.<br>The second part examines the structural alternatives of the CCA tax vehicle.<br>The third part addresses the CCA concept itsel
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33

Havemann, Luke Paul. "Greening upstream South Africa : a critical and comparative enviro-legal analysis of the offshore oil and gas activities of the United Kingdom and South Africa." Thesis, University of Aberdeen, 2010. http://digitool.abdn.ac.uk:80/webclient/DeliveryManager?pid=158422.

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This thesis essentially constitutes an analysis of laws designed to protect the marine environment from the pollution arising from the exploitation of offshore oil and gas reserves, Chapter 2 addresses not only the origin and nature of oil and gas, but also the techniques employed in surveying for and producing these energy forms. Chapters 3 and 4, in turn, outline the history of offshore operations in South Africa and the UK, respectively, with regard, <i>inter alia</i>, to the location, size and economic significance of these operations. In order to properly address the South African legal f
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Littlewood, Michael. "Taxation without representation : the history of Hong Kong's troublingly successful tax system /." Thesis, Hong Kong : University of Hong Kong, 2001. http://sunzi.lib.hku.hk/hkuto/record.jsp?B22719829.

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35

Moran, Susan Jane. "The influence of the 1968-1975 Congressional reforms on legislative policy-making : the development of the oil-pricing provision of the Energy Policy and Conservation Act (1975)." Thesis, University of Oxford, 1986. http://ora.ox.ac.uk/objects/uuid:3398b8d3-45ae-4706-b094-692a7ba0f827.

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Congressional reform is the focus of my study. Congress (but primarily the House of Representatives) attempted to reform its workings from 1968 through 1975, so it might be more effective in developing comprehensive policies on national issues, and more independent of the executive branch. Reform raised expectations that the legislature would reassert its policy-making role, which had diminished during the preceding thirty years. My study examines the influence of these changes on the congressional decision-making process, including their impact on the important role played by external actors,
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Wesson, Nicolene. "Die invloed van Internet op die toepaslikheid van die bronreels in terme van die Inkomstebelastingwet, No. 58 van 1962." Thesis, Stellenbosch : Stellenbosch University, 1999. http://hdl.handle.net/10019.1/51219.

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Thesis (MCom)--Stellenbosch University, 1999.<br>ENGLISH ABSTRACT: lt is internationally accepted that Internet is the trade route of the future. Although Internet trading is still in its infancy the effect of Internet on taxation needs to be adressed. Internet defies geographic borders and leads to the questioning of the principles underlying income tax. Income tax principles are traditionally based on the existence of some form of physical presence (either residency, source of income or that of a permanent establishment) in a jurisdiction before tax can be levied. The fact that Inter
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Nilsson, Therese. "Taxation on loans from foreign undertakings : The Swedish legislation and its compatibility with the freedom of establishment within the European Union." Thesis, Jönköping University, JIBS, Commercial Law, 2010. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-12277.

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<p>On January 1, 2010, the Swedish government changed the national rule on taxation of loans between Swedish companies and their shareholders to also comprise loans granted by foreign companies. By changing the rule to also comprise foreign companies, the government aimed to eliminate the newly discovered tax planning which is carried out by an owner establishing a holding company in another Member State from which he lends tax-free means for private consumption. These proceedings result in major tax revenue losses for Sweden since the shareholder’s income was not taxable in Sweden before the
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Georgescu, Ana-Luiza. "Certain tax aspects of corporate divisive reorganizations in Canada and the UK." Thesis, McGill University, 2004. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=81470.

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A divisive reorganization involves a series of transactions having as effect and purpose the division of the trading activities carried on by a single company or group of companies between two or more companies or groups of companies. This can be achieved by a sale of assets or by a transfer of shares belonging to the corporation to be divided, which would generally give rise to taxable capital gains.<br>The thesis analyzes the tax implications of these two approaches, with particular focus on the latter, attempting a comparative view over the UK and Canadian relevant provisions. The tw
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Siame, Chilengwe George. "Broadening the tax base: a case for the informal real estate sector in Zambia." Thesis, Rhodes University, 2010. http://hdl.handle.net/10962/d1003852.

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The main objective of the study was to analyze the potential tax collection from the informal rental housing market in Zambia, using household level rental housing data collected for the Lusaka Urban District by the Central Statistical Office (CSO) as a basis for computation and extrapolation to the national level. This data was used to analyze household monthly expenditure on housing (rent), the total number of households in rented accommodation, and the tax regime applicable on rental income, to estimate the potential tax revenue that could be realized from this emerging sector. The estimate
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Dike, Samuel Chisa. "Legislating security of supply of petroleum resources in Nigeria : current practice, new direction and lessons from Brazil, Norway and the UK." Thesis, University of Aberdeen, 2014. http://digitool.abdn.ac.uk:80/webclient/DeliveryManager?pid=211108.

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Security of supply of petroleum is a serious challenge in Nigeria that seems to lack any known legal remedy. It is a paradox that Nigeria is experiencing inadequate supply of petroleum resources for domestic consumption despite the abundance of oil and gas reserves in the country. Past efforts in the search for solutions through which to address this challenge have largely been political, quick fixes and episodic in nature. This research aims to address this challenge by looking for a possible solution towards the direction of the law-Petroleum Act 1969, which fundamentally regulates the indus
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Gumbo, Wadzanai Charisma. "The taxation of the “sharing economy” in South Africa." Thesis, Rhodes University, 2019. http://hdl.handle.net/10962/64045.

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The research examined whether the services provided by the “sharing economy” platforms are adequately dealt with by the current South African tax systems. In addressing this main goal, the research analysed how the South African tax systems deal with the income and expenses of Uber, Airbnb and their respective service providers. The research also investigated how South Africa could classify “sharing economy” workers and how this would affect the deductibility of the worker’s expenses. A brief analysis was made of the taxation of the “sharing economy” businesses in Australia and the United Stat
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Azzi, John. "The role of CFC legislation in protecting Australia's domestic income tax base." Thesis, The University of Sydney, 1997. http://hdl.handle.net/2123/20011.

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Fourie, Catherine. "Fairness and efficacy of the penalty provisions in the Tax Administration Act 28 of 2011." Thesis, Nelson Mandela Metropolitan University, 2016. http://hdl.handle.net/10948/12426.

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The purpose of this treatise was to examine the fairness and efficacy of the penalty provisions in the Tax Administration Act (the Act). An integrative literature review research method was used. The study commenced with a review of the local and international literature on tax compliance and the fairness and efficacy of penalties. This was followed by a study of the stated objectives of the Fiscus in respect of the strategy and approach to maintaining and improving taxpayer compliance and an analysis of the penalty regime of the Act. A comparative analysis was then performed of the relevant t
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Yeung, Jackson Kit Shing. "Can arbitration & ADR be practically adopted in resolving disputes for oil & gas trading in mainland China?" access abstract and table of contents access full-text, 2005. http://libweb.cityu.edu.hk/cgi-bin/ezdb/dissert.pl?ma-slw-b20835917a.pdf.

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Froom, Natalie Marie. "Domestic tax law v double tax treaties in the context of controlled foreign companies." Thesis, Nelson Mandela Metropolitan University, 2014. http://hdl.handle.net/10948/3559.

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The South African fiscal legislators have found it necessary to introduce anti-avoidance legislation which governs controlled foreign companies in order to counteract schemes devised by taxpayers where companies are established outside South Africa for the purpose of diverting income from the South African fiscal net. Whilst the enforcement of such legislation does have merit in that the intention behind the introduction of such domestic legislation is to prevent the erosion of the South African tax base, it is submitted that this does pose a problem from an international perspective. The obje
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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 policie
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Bojang, Buba. "The status and expanding role of joint development of common or transboundary oil and gas resources in international law." Thesis, University of Aberdeen, 2017. http://digitool.abdn.ac.uk:80/webclient/DeliveryManager?pid=236935.

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The growth and expansion of Joint Development Agreements, which promote the joint development of common or transboundary petroleum deposits between countries with opposite or adjacent coastlines are an indication that the status of the obligation to jointly develop common or transboundary oil and gas resources as a rule of customary international law may no longer be doubtful. This research examines the origin and evolution of Joint Development (JD) to determine its status in international law, including the law of the sea. It also explores the concept of shared natural resources in internatio
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Morocco-Clarke, Susan Ayodele. "Improving environmental protection within the Nigerian oil and gas industry : long term national solutions, short term international solutions?" Thesis, University of Aberdeen, 2012. http://digitool.abdn.ac.uk:80/webclient/DeliveryManager?pid=186680.

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This thesis carries out a comparative analysis between the modes of operation adopted in the oil and gas industries of Nigeria and developed countries (with an emphasis on the UK), examining in the process, the existing and persistent problem of pollution which has plagued the Nigerian State and gone virtually unchecked for over five decades, and dealing with the lacunae in the law currently in place in Nigeria. This analysis is carried out to ascertain the possibility of improving environmental protection in Nigeria. A course is charted through the history and development of the Nigerian oil
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Scruggs, Larry Glen. "Unrelated Business Enterprise and Unfair Business Competition Issues Facing Nonprofit Organizations." PDXScholar, 1996. https://pdxscholar.library.pdx.edu/open_access_etds/1361.

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Unrelated business enterprises have been an appropriate way for nonprofit organizations to generate income since the first income tax was enacted into law. The Internal Revenue Act of 1950 clarified this opportunity and enacted the Unrelated Business Income Tax to ensure that fair competition existed between nonprofits and for profit organizations. Nonprofit organizations conducting unrelated business enterprises are faced with a dilemma: it is legal for them to conduct such enterprises but if they do so they face potential litigation from for profit business for unfair competition and/or pote
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Van, Wyk Ellane. "Belasting op buitelandse dividende in die Republiek van Suid-Afrika." Thesis, Stellenbosch : Stellenbosch University, 2003. http://hdl.handle.net/10019.1/19901.

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Thesis (MRek) -- Stellenbosch University, 2003.<br>ENGLISH ABSTRACT: The introduction of section 9E in the Income Tax Act, NO.58 of 1962 (hereafter "the Act") became effective on 23 February 2000. The main reasons for the introduction of this was, inter alia, to broaden the tax base and to phase in the residency basis of taxation. Consequently are the foreign dividend rules of section 9E interrelated to the foreign income rules of section 90, being the application of the residence basis of taxation. The main objective of this study is to investigate the taxation of foreign dividends in
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