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1
FRANCISCO, MARCELA LOBO. "COMPARISON BETWEEN PETROLEUM TAXATION: CONCESSIONARY AND SHARING." PONTIFÍCIA UNIVERSIDADE CATÓLICA DO RIO DE JANEIRO, 2011. http://www.maxwell.vrac.puc-rio.br/Busca_etds.php?strSecao=resultado&nrSeq=18565@1.
Full textAbstract:
A escolha, por parte dos governos, de qual regime de taxação adotar sobre o
petróleo determina como a renda gerada pela atividade de exploração e produção
deste é dividida entre o Estado e os investidores particulares. Por parte dos
Estados é extremamente importante a escolha de um regime que não desestimule
os investidores particulares, e que por outro lado seja capaz de gerar renda
suficiente para impulsionar a sua economia e produzir o bem estar da sua
população. Este trabalho faz um estudo dos principais regimes de taxação sobre o
petróleo identificando como a renda gerada pelo campo é distribuída entre o
governo e os investidores particulares, e calcula a exposição ao risco dos agentes
para ambos os regimes estudados. O objetivo é verificar se estes atendem aos
principais requisitos que um regime deve ter para ser considerado eficiente
(simplicidade e neutralidade) e se existe uma relação entre o tipo de regime e as
variáveis citadas acima. Os principais regimes de taxação existentes no mundo são
o regime de concessão e o regime de partilha. Foram estudados os regimes
vigentes na Austrália, na Noruega, no Brasil e na Indonésia. Os três primeiros
países adotam o regime de concessão e o último adota o regime de partilha.
Dentre os regimes estudados o da Austrália mostrou ser o mais simples, sendo a
remuneração do governo feita através de duas taxas, e o da Indonésia o mais
complexo, onde a remuneração do governo é feita através de cinco taxas. O Brasil
apresenta um regime considerado simples, sendo a receita do governo feita através
de três taxas. A distribuição da renda gerada pela atividade de exploração e
produção do petróleo é mais equitativa na Austrália onde os investidores
particulares recebem cerca de 16,6% e o governo 88,4%. No Brasil cabe aos
investidores particulares 9,16% e ao governo 90,84%. A Noruega e a Indonésia
apresentaram regimes de taxação que penalizam o investidor particular, o campo
apresenta um VPL positivo antes do pagamento das taxas e negativo após. O Brasil e a Austrália apresentaram VPL positivo antes e depois do pagamento das
taxas. Através dos resultados encontrados pode-se verificar que não existe uma
relação entre o tipo de regime e as seguintes variáveis: equidade na distribuição da
renda, neutralidade e exposição ao risco do investidor particular e do governo.
Países que adotam o mesmo regime, de concessão, apresentaram características
diferentes: Noruega mostrou ser um regime que penaliza o investidor particular e
a Austrália um que possui a distribuição de renda mais equitativa. Em relação ao
risco o que apresentou um maior risco para o investidor particular foi a Indonésia
e o que apresentou menor risco foi a Austrália. O Brasil em ambos os casos ficou
em terceiro lugar. Sendo assim, um regime em si não pode ser considerado mais
eficiente do que outro. A questão principal é a forma como a taxação é feita
dentro de cada regime. O foco da discussão deveria ser como o petróleo vai ser
taxado dentro do atual regime (concessão), dado que agora o volume de reservas
do país atingiu um nível inédito, e não qual o regime de taxação adotar.Government choice of which taxation regime to adopt on oil determines how the revenue generated by the activity of exploring and producing this oil is shared between the State and private investors. From the point of view of the State, it is extremely important to choose a regime that does not detract private investors and that is also capable of generating enough revenue to bolster the country´s economy and promote the well-being of its population. The present work studies the main taxation regimes on oil, identifying how the income generated by this product is distributed between government and private investors. It also calculates the level of risk for agents in both regimes analysed. The aim is to verify if these regimes comply with the main requirements necessary for a regime to be considered efficient − simplicity and neutrality – and if there is a relation between the kind of regime and the variables mentioned above.The main taxation regimes in the world are concession and sharing. The regimes adopted by Australia, Norway, Brazil and Indonesia were studied. The first three countries adopt the concession regime, while the latter adopts the sharing one. The Australian regime – in which government remuneration was obtained by two taxes − was the simplest of all analysed regimes, while that of Indonesia – in which government remuneration was obtained by five taxes − was the most complex. The Brazilian regime is considered to be simple: government revenue is obtained by means of three taxes. The distribution of the revenue generated by oil exploration and production is more balanced in Australia, where private investors receive around 16.6% and the government around 88.4%. In Brazil private investors gain 9.16% and the government 90.84%.The regimes in Norway and Indonesia penalize the private investor; the field presents a positive net current value prior to taxes and negative after taxes. Brazil and Australia displayed positive net current value prior to and after taxes levied. The findings suggest that there is no relation between the kind of regime and the following variables: equity in income distribution, neutrality, and investor and government risk. Countries that adopt the same regime – concession – presented different characteristics. The regime adopted by Norway penalized the private investor, while that of Australia distributed revenues more equitably. As regards risk, the regime with greatest risks for private investors was the Indonesian, while the one with least risks was the Australian. Brazil ranked third in both categories. Thus, a regime cannot be considered more efficient than another. The main issue is how taxes are levied within each regime. Given that the Brazilian oil reserve has reached unprecedented levels, discussion should focus on how oil will be taxed in the present regime (concession), rather than on the taxation regime adopted.
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Hassim, Bilal. "A critical analysis of the fiscal incentives available in the renewable energy - a comparison between South Africa, India, China and Brazil." Master's thesis, University of Cape Town, 2017. http://hdl.handle.net/11427/25321.
Full textAbstract:
South Africa relies significantly on the use of non-renewable resources to generate its electricity requirements. The release of carbon dioxide and other harmful gasses during the process of electricity generation has a negative impact on the quality of human and animal health and wellbeing. The South African renewable energy sector is currently in its infancy in comparison to the global renewable energy sector. A brief analysis and comparison of the renewable energy sectors of the other countries selected in this dissertation (i.e. Brazil, China and India) will be performed to highlight the common challenges in these countries in an effort to demonstrate the relevance and importance of the tax and limited related incentives to assist in reducing these challenges and increase the use of renewable energy resources in electricity power plants. Once the relevance and importance of tax and related incentives are highlighted, this dissertation analyses and examines the specific tax incentives available to enterprises operating in the renewable energy sector in South Africa, India, China and Brazil. Based on the analysis, recommendations and/or enhancements to the current corporate tax incentives available in South Africa will be discussed in detail. This dissertation will also discuss whether any of the recommendations and/or enhancements could be incorporated into the existing South African Special Economic Zones Act. As there are 108 solar and wind energy power plant being constructed in Brazil, but no significant corporate tax incentives currently available to qualifying taxpayers, the regulatory policy setting out the renewable energy targets and how it will be achieved is an important consideration. It was found that if there were periodic updates to the regulatory policy and it was mandatory for electricity utility companies (such as Eskom) to ensure that there is a mix between renewable energy and non-renewable energy sources based on the regulatory policy, it would ensure that the delays currently being experienced in the expansion of the renewable energy sector would be significantly reduced. This dissertation found further that the accelerated capital allowances available to qualifying taxpayers in South Africa are considerably more favourable than similar accelerated capital allowances available in the other countries selected in this dissertation.
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Futter, Alison Jane. "The taxation of oil and gas exploration and production in South Africa : a critical comparison of the OP26 and Tenth Schedule tax regimes." Master's thesis, University of Cape Town, 2010. http://hdl.handle.net/11427/10488.
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Includes abstract.Includes bibliographical references (leaves 112-123).
This dissertation provides a clear exposition of difficult legal tracts of the Income Tax Act, OP26 prospecting leases, OP26 mining leases and OP26 prospecting sub-lease agreements and the Tenth Schedule of the Income Tax Act.
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Stemmet, Vicki. "Multiple taxes levied on deceased estates:A comparison of the determination of the value and the taxation of limited interests for estate duty,capital gains tax and value-added tax." Master's thesis, University of Cape Town, 2018. http://hdl.handle.net/11427/29277.
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South Africa has one of the highest wealth inequality rates in the world, and there is a dire need for practical methods of redistribution of wealth in South Africa (SA). For this reason, the need for wealth tax in SA is undeniable however the multiple taxes imposed on deceased estates have generated discussions, with many being of the opinion that the taxes imposed on deceased estates are excessive. The main objective of this research is to discuss the multiple taxes levied on certain limited interests in property on death. The imposition of estate duty (ED), capital gains tax (CGT) and value-added tax (VAT) on usufructuary and fiduciary interests in deceased estates were examined. The valuation methods and taxation of these limited interests for the aforementioned taxes were compared to determine if they are stream-lined and if any relief is provided between taxes. It was found that valuation methods and taxation methods are not stream-lined and it appears that no interplay exists between taxes. The substantial differences in valuation and taxation methods between taxes results in the same asset being taxed at different values for each tax. This places a heavy administrative burden on the executors of deceased estates and goes against the characteristics of an efficient tax system which should be fair, simple and easy to administer. Due to the complexities involved in the different tax computations of these rights, it was not possible to provide a conclusive answer regarding whether or not taxes imposed on deceased estates are fair or excessive. In conclusion, however, recommendations have been made to align deductions and valuation methods across taxes in order to bring about transparency which would enable the determination of whether or not the tax burden is excessive and identification of any weaknesses in the tax systems. The alignment could ultimately result in a more efficient tax system, and could address and resolve the concerns regarding the levying of multiple taxes on the same asset in deceased estates.
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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 study compared the two jurisdictions based on the above mentioned areas to determine similarities or differences. The study concluded with recommendations, these being that South Africa should assess the feasibility of providing greater State provided retirement funding by possibly including a mandatory contribution, such as that used by the UK for its single-tier flat rate New State Pension. A further recommendation was that South Africa should encourage greater provision of private retirement funding by considering even greater tax deductions for contributions.
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Zábrodský, Jan. "Komparace daňového zatížení příjmů ze závislé činnosti a z podnikání ve vybraných zemích EU." Master's thesis, Vysoká škola ekonomická v Praze, 2010. http://www.nusl.cz/ntk/nusl-114557.
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This thesis addresses the taxation of employment and entrepreneurship. Based on a comparative analysis, the author compares the taxation of individuals in selected countries of European Union including the Czech Republic. The aim of the thesis is to evaluate the differences in taxation of employed and self-employed tax payers in four tax systems (Czech Republic, Denmark, Ireland, and Germany). In the first part of the thesis, the author describes the current taxation framework of employed and self-employed tax payers. The macroeconomic comparisons are based on the most recent comprehensive data available from 2009. In order to compare the taxation on the microeconomic level, a complete calculation example is conducted for each selected state, followed by the analysis and discussion of the implications. The calculations for each state are conducted in accordance with the state's tax regulations. The results of the analysis shows that, in the Czech Republic, employees are disadvantaged compared to self-employed by higher taxations, which are not compensated by the possibility of the individualisation of the tax bases and the tax itself. Based on the results of the comparative analysis, the author suggests that specific modifications of tax regulations are required to reduce the differences in the taxation of employed and self-employed in the Czech Republic.
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Donaldson, Peter Allen. "An analysis of the appropriateness of the four funds approach for the taxation of life insurers in South Africa including a qualitative comparison to the recently enacted approach adopted in New Zealand and recommendations for improvement to the approach." Master's thesis, University of Cape Town, 2011. http://hdl.handle.net/11427/11804.
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Section 29A of the Income Tax Act No. 58 of 1962 contains a special set of rules for the taxation of life insurers. These rules were originally enacted in 1993 and are commonly referred to as the four funds approach. The rules have remained largely unchanged since their original enactment despite ongoing changes in the life insurance industry in particular with regards to new product offerings.
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Mausling, Hermana. "The effectiveness of the tenth schedule tax regime to attract and retain foreign investment: The current issues and uncertainties experienced within the tenth schedule tax regime and a comparison between the incentives provided by the tenth schedule and those provided by the Ghana oil and gas tax regim." Master's thesis, University of Cape Town, 2016. http://hdl.handle.net/11427/21749.
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In South Africa, oil and gas companies are subject to the ordinary tax rules within the Income Tax Act 58 of 1962 ("the Act"), but enjoy certain tax concessions within the Tenth Schedule to the Act. The main reason for introducing the Tenth Schedule was to create certainty and transparency for oil and gas exploration and production with the aim to secure foreign investment (National Treasury, 2006:15). Considering the growth potential of South Africa's oil and gas industry and the fact that the Tenth Schedule was introduced to create certainty and transparency in the hopes of securing foreign investment, this dissertation evaluates whether the Tenth Schedule achieves its aim of providing certainty and transparency in order to attract and retain foreign investment in the oil and gas industry. Furthermore, this dissertation identifies issues and uncertainties found within the Tenth Schedule which could hinder such foreign investment. Finally, as countries are in competition with one another to attract foreign investment, this dissertation evaluates how the incentives provided by the Tenth Schedule compare to the incentives provided by Ghana's oil and gas tax regime.
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Smit, Nell-Mari. "An international comparison on the impact of the extended life expectancy of natural persons for taxation purposes." Diss., University of Pretoria, 2012. http://hdl.handle.net/2263/26428.
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The increase in the life expectancy of natural persons has become a worldwide phenomenon. People live longer and need income for longer periods of time. Individuals need to start saving for their retirement early in life while still part of the workforce. Insufficient retirement savings lead to individuals not having sufficient income for their retirement. People become dependent on the government for assistance in paying for their day-to-day living expenses, leading to increases in social grants payable by the government. In South Africa the National Treasury needs to budget through taxation for the increase in the old age pension, which increases government expenditure. Additional income tax will therefore need to be raised to ensure that the national deficit does not increase further. Personal income taxes will directly be affected by the increase in the life expectancy. Research has been done internationally on the increase in life expectancy and the possible effect on the governments of those countries. No research has, however, been done in such detail in South Africa. This study provided information on the increase in the life expectancy of the South African population and the effect on the increase of old age pension as a social grant expense paid by the Government to qualifying beneficiaries. The aim of this study was to gain insight in the increase in the number of elderly people, those individuals aged 60 years and older, and the relation between this increase and the increase in the number of old age pension beneficiaries together with the increase in the budgeted expenses by the Government for old age pension. From a theoretical perspective, this study aimed to identify the possibility of increasing the retirement age to help people receive an income from employment for longer and to provide for themselves during the longer years in retirement. Finally the study aimed to assess this impact on taxation. A number of factors play a role in the increase of the number of old age pension beneficiaries and the resulting old age pension expense in the government budget. This study only focused on the role that the increase in life expectancy plays. AFRIKAANS : Die toename in die lewensverwagting van natuurlike persone het ’n wêreldwye verskynsel geword. Mense leef langer en moet ’n inkomste vir ’n baie langer tydperk hê. Individue moet reeds vroeg, terwyl hulle nog deel is van die werksmag, begin spaar vir hul aftrede. Onvoldoende aftreefondse lei daartoe dat pensioenarisse nie voldoende inkomste tydens hul aftrede verdien nie. Hierdie tekort lei daartoe dat individue afhanklik is van die regering om hulle by te staan vir die betaling van daaglikse uitgawes. Dit lei tot die verhoging in die maatskaplike toelaes wat deur die regering betaal word. In Suid-Afrika moet die Nasionale Tesourie in die begroting voorsiening maak vir die toename in die ouderdomspensioen wat tot ’n toename in regeringsuitgawes lei. Ekstra inkomste moet ook verkry word om te verseker dat die nasionale tekort nie verder toeneem nie. Persoonlike inkomstebelasting word regstreeks hierdeur beïnvloed. Internasionale navorsing is gedoen op die toename in lewensverwagting en die moontlike invloed op die regerings van daardie lande. Soortgelyke navorsing is egter nog nie in Suid-Afrika gedoen nie. Dié studie bied meer inligting oor die toename in lewensverwagting van die Suid-Afrikaanse bevolking en die effek daarvan op die toename in die ouderdomspensioen as ’n maatskaplike toelaag wat deur die regering betaal word aan begunstigdes wat daarvoor kwalifiseer. Die doel van hierdie studie was om insig te verkry in die toename in die aantal bejaardes, individue van 60 jaar en ouer, en die verwantskap tussen hierdie toename en die toename in die aantal ouderdomspensioen begunstigdes asook die begrote regeringsuitgawe vir ouderdomspensioene. Die studie het gepoog om vanuit ’n teoretiese oogpunt te kyk na die moontlikheid om die aftreeouderdom te verhoog sodat mense langer inkomste kan verdien en vir hulleself kan sorg in die langer aftreetydperk. Die studie het ook gekyk na die invloed hiervan op belasting. Verskeie faktore speel ’n rol in die groei van die aantal individue wat ouderdomspensioen ontvang en gepaardgaande toename in die ouderdomspensioenbegroting van die regering. Die studie het slegs gefokus op die rol wat die verhoging in lewensverwagting speel.Dissertation (MCom)--University of Pretoria, 2012.
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Gabriel, Keshia C. "Comparison on the rules of origin for customs and excise." Diss., University of Pretoria, 2014. http://hdl.handle.net/2263/46187.
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South Africa is currently an emerging economy and has various trade agreements with the United States of America and the United Kingdom according to which South Africa enjoys different preferential rules of origin. In some respects, current customs and excise legislation relating to rules of origin places South Africa at a disadvantage in the global arena. In some cases, preferential rules of origin with developed countries benefit South Africa little if they are not properly structured, or if the rules of various trade agreements contradict each other.
The aim of this study was to ascertain whether South Africa’s rules of origin are sufficiently aligned with those of more developed economies to improve the economy, thereby increasing trade growth and tax revenue. This study compared the South African rules of origin with rules of origin that are applied in another developing country, namely Brazil, as well as to those applied in two developed countries, namely the United Kingdom and the United States. To illustrate the application of the rules of origin, this study focused specifically on rules of origin applicable to individual quick frozen poultry. This comparative study identified similarities and differences between the countries, and noted possible improvements to South African customs and excise tax legislation for this industry. It was found that the rules of origin applied in South Africa are similar in some respects to those used in the UK. An improvement that South Africa could make is to minimise the number of rules in effect by negotiating better preferential rates of duty across more than one country. South Africa could also ensure that it can comply with all obligatory conditions of trade agreements entered into to avoid under-utilisation of the benefits of a trade agreement. By adopting or adapting some of the advantages of the rules of origin in the countries chosen for comparison, South Africa can grow its international trade and generate increased tax revenue to support the government’s revenue income demand.Dissertation (MCom)--University of Pretoria, 2014.
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Němcová, Jana. "Daně a daňová politika v zemích EU." Master's thesis, Vysoká škola ekonomická v Praze, 2007. http://www.nusl.cz/ntk/nusl-12076.
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This thesis describes taxes, analyses tax-to-GDP ratio in the European Union countries. Next aim is to compare structure and volume of taxation in chosen European Union countries and the Czech republic and also appreciate plan of tax coordination.
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Fourie, Leonie. "A comparison between the South African "source rules" in relation to income tax and the "permanent establishment rules" as contained in double taxation agreements." Thesis, Rhodes University, 2008. http://hdl.handle.net/10962/d1008203.
Full textAbstract:
South Africa's right to tax the income of a non-resident is determined in terms of the South African "source rules" established by court decisions in relation to the imposition of tax in terms of the Income Tax Act. Unless a non-resident's income is captured by the South African "source rules" (on the basis that hi slits income is derived from a South African source), South Africa would have no right to tax such income, even if such non-resident creates a permanent establishment in South Africa by performing business activities within South Africa which could be considered essential (but not dominant) in nature. In such scenario the activities performed by the non-resident in South Africa may utilise the natural resources and the infrastructure of South Africa, but the South African fiscus would be deprived of the right to any tax revenues attributable to the income produced partly by such activities within South Africa. The South African "source rules" refer only to the main or dominant activities giving rise to the income for the purpose of determining the source of such income (and accordingly the right to tax such income). On the other hand, the "permanent establishment rules" as set out under the Organisation for Economic Cooperation and Development Model Tax Convention on Income and on Capital refer to all the taxpayer's essential business activities for the purpose of determining whether or not such activities create a pennanent establishment. The result of the narrow nature of the South African "source rules" is that, under certain circumstances, the South African fiscus would not necessarily be granted the right to tax all income produced partly within South Africa. The research demonstrated that incorporating the principles underlying the "pennanent establishment rules" into South African legislation would be a reasonable and logical solution to the problem of detennining the source of income. In so doing, the South African "source rules" would determine the source of income, and consequently South Africa's taxing rights, with reference to the essential business activities giving rise to such income. In such case South Africa would be afforded the right to tax the income of a non-resident in the event that it performs any of its essential business activities within South Africa, albeit not the dominant or main activities giving rise to the income.
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Commendatore, Pasquale, and Ingrid Kubin. "Source versus Residence. A comparison from a New Economic Geography perspective." SFB International Tax Coordination, WU Vienna University of Economics and Business, 2007. http://epub.wu.ac.at/538/1/document.pdf.
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Recently, issues of international taxation have also been analysed from a New Economic Geography perspective. These discussions show that agglomerative forces play a non negligible role. In the paper, we introduce explicitly taxation into a Footloose Capital Model and compare implications of taxation according to the residence principle and the source principle from a New Economic Geography perspective. We confirm that agglomerative effects change the results substantially compared to the standard analysis and that the two taxation principles have different implications for industry agglomeration. (author's abstract)Series: Discussion Papers SFB International Tax Coordination
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Korzhenevych, Artem, and Sebastian Langer. "The Flypaper Effect in Germany: An East-West Comparison." Saechsische Landesbibliothek- Staats- und Universitaetsbibliothek Dresden, 2016. http://nbn-resolving.de/urn:nbn:de:bsz:14-qucosa-213629.
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We investigate the effect of general-purpose transfers on different expenditure categories and tax rates in the municipalities of Saxony (eastern Germany) and North Rhine-Westphalia (western Germany). Findings from the panel data analysis suggest the existence of the “flypaper effect” – municipalities use transfers to increase expenditures but do not reduce taxes. For most expenditure subcategories the estimated coefficients are alike, suggesting similarity of spending priorities in the two federal states despite the differences in the transfer dependency. Targeted support of eastern municipalities could potentially explain few identified differences in the spending behavior.
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John, Jiří. "Komparace zdanění motorových vozidel v zemích EU." Master's thesis, Vysoká škola ekonomická v Praze, 2011. http://www.nusl.cz/ntk/nusl-124596.
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This Master's thesis analyses the taxation of motor vehicle in the European Union. The main goal of the thesis is to describe individual taxes imposed on cars, compare the amount of taxation within the European Union. The system of taxation of motor vehicles is illustrated in several member states of the European Union. In conclusion is evaluated the impact of harmonization on taxation of cars.
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Moholola, Johannes Makgokolla. "A critical comparison of tax incentives for small, medium and micro enterprises between South Africa and Australia." Diss., University of Pretoria, 2010. http://hdl.handle.net/2263/31068.
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The South African Revenue Service (SARS) introduced tax incentives for the small, medium and micro enterprises (SMMEs) in 2001. These incentives were introduced to assist small business in stimulating economic activity, creating jobs and alleviating poverty. This policy decision is not unique to South Africa. Many other countries offer incentives to small businesses for a variety of reasons, which may differ from country to country. However, it is generally understood that small businesses often face challenges which require the State to intervene in the form of tax incentives. South Africa operates on a global economic platform. It is imperative that its efforts are comparable against those of its counterparts so that it can assess its situation and be able to channel resources in the right direction. This study uses a qualitative systematic literature review to compare the tax incentives offered to SMMEs in South Africa and Australia .Australia has been chosen because it is a developed country and also because it has a mature and simplified legislation. The findings of this study show that South Africa has provided good incentives, particularly in the area of attracting small businesses into the tax base but once these small businesses are in the base, there is nothing to ensure that they grow. On the other hand, Australia has not done much to bring small businesses into the tax base, but it provides good incentives, sufficient to enable business growth for those already in the system. One of the challenges faced by many small businesses is cash flow resources. This study has found that Australia’s tax incentives empower small businesses in the area of cash flow, as compared with the situation in South Africa. Future research studies should investigate the extent to which the respective small businesses are aware of the tax incentives available to them. That is, it must be established how far each country has gone in ensuring that small businesses are familiar with all the incentives at their disposal.Die Suid-Afrikaanse Inkomstediens (SAID) het belastingaansporings skemas vir die klein, medium en makro-ondernemings (KMMOs) in 2001 ingestel. Hierdie aansporings is ingestel om die klein besighede te help om ekonomiese aktiwiteite te stimuleer, werk te skep, asook om armoede te verlig. Hierdie beleidsbesluit is nie uniek aan Suid-Afrika nie. Menige ander lande bied aansporings aan die klein ondernemings vir ‘n verskeidenheid van redes. Alhoewel hierdie redes kan verskil van land tot land, word dit algemeen verstaan dat klein ondernemings dikwels uitdagings ervaar wat vereis dat die staat ingryp in die vorm van belasting-aansporings. Suid-Afrika werk in ‘n wêreldwye ekonomiese platform. Dit is noodsaaklik dat Suid-Afrika se pogings met die van sy eweknieë vergelyk word om sodoende die huidige situasie te evalueer en in staat te wees om hulpbronne in die regte areas beskikbaar te stel. Hierdie studie maak gebruik van ‘n kwalitatiewe sistematiese literatuur oorsig om die belastingaansporings in beide Suid-Afrika en Australië vir KMMO’s te vergelyk. Australië is gekies weens die feit dat dit ‘n ontwikkelde land is en ook omdat dit oor goed ontwikkelde en eenvoudige wetgewing beskik. Die bevindinge van hierdie studie toon dat Suid-Afrika goeie belastingaansporings het, veral op die gebied om die klein ondernemings in die belastingbasis in te trek, maar wanneer hierdie klein ondernemings in die basis is, is daar niks in plek om te verseker dat hulle verder groei nie. Aan die ander kant, het Australië nie veel gedoen om klein besighede in die belastingbasis belastingbasis in te bring nie, maar Australië bied goeie voordele wat tot besigheidsgroei lei vir diegene wat reeds in die belastingsbasis ingeskakel is. Een van die uitdagings van baie klein besighede is kontantvloeibronne. Hierdie studie het bevind dat, Australië se belastingaansporings, die klein ondernemings se kontantvloei bevorder in teenstelling met die posisie in Suid-Afrika. Toekomstige Toekomstige navorsingstudies moet die mate waartoe die onderskeie klein ondernemings bewus is van die belastingaansporingsskemas wat beskikbaar is, ondersoek. Dit wil sê, daar moet vasgestel word hoe ver elke land gegaan het om te verseker dat kleinondernemings vertroud is met al die moontlikhede tot hulle beskikking.
Dissertation (MCom)--University of Pretoria, 2011.
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Stoll-Davey, Camille. "Global comparison of hedge fund regulations." Thesis, University of Oxford, 2008. http://ora.ox.ac.uk/objects/uuid:d08de3ea-6818-46cf-96b1-1bbb785a7504.
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The regulation of hedge funds has been at the centre of a global policy debate for much of the past decade. Several factors feature in this debate including the magnitude of current global investments in hedge funds and the potential of hedge funds to both generate wealth and destabilise financial markets. The first part of the thesis describes the nature of hedge funds and locates the work in relation to four elements in existing theory including regulatory competition theory, the concept of differential mobility as identified by Musgrave, Kane’s concept of the regulatory dialectic between regulators and regulatees, and the concept of unique sets of trust and confidence factors that individual jurisdictions convey to the market. It also identifies a series of questions that de-limit the scope of the present work. These include whether there is evidence that regulatory competition occurs in the context of the provision of domicile for hedge funds, what are the factors which account for the current global distribution of hedge fund domicile, what latitude for regulatory competition is available to jurisdictions competing to provide the domicile for hedge funds, how is such latitude shaped by factors intrinsic and extrinsic to the competing jurisdictions, and why do the more powerful onshore jurisdictions competing to provide the domicile for hedge funds not shut down their smaller and weaker competitors? The second part of the thesis examines the regulatory environment for hedge funds in three so-called offshore jurisdictions, specifically the Cayman Islands, Bermuda and the British Virgin Islands, as well as two onshore jurisdictions, specifically the United Kingdom and the United States. The final section presents a series of conclusions and their implications for both regulatory competition theory and policy.
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Heger, Václav. "Komparace daňového systému České republiky a Spojených států amerických." Master's thesis, Vysoké učení technické v Brně. Fakulta podnikatelská, 2013. http://www.nusl.cz/ntk/nusl-224291.
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This thesis describes the tax systems in the Czech Republic and the United States of America and their subsequent comparison. The work is divided into three parts, namely the theoretical, analytical and practical part. In the first section we describe the basic concepts and issues. In the second part of the thesis are first described the tax systems of the Czech Republic and the United States, followed by their evaluation and comparison, the accent is put on the taxation of personal incomes. In the third part of the thesis the author's attention is pointed to suggestions and recommendations leading to tax optimization of tax burden of taxpayer´s selected category.
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Antalova, Livia. "Contemporary Flat-Tax Reforms in Eastern Europe. Causes of Diverse Approaches : A comparison of Slovakia, Czech Republic and Germany." SFB International Tax Coordination, WU Vienna University of Economics and Business, 2010. http://epub.wu.ac.at/1626/1/document.pdf.
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The paper deals with the issue of contemporary flat-tax reforms in Eastern Europe and aims to account for the different approaches that various European countries adopted towards the idea of a flat-tax. Empirically, the work is based on detailed studies of Slovakia, the Czech Republic and Germany. The analysis considers three factors being decisive for the flat-tax feasibility: 1./ party system institutionalization, 2./ coalition/opposition cohesiveness, 3./ labor union institutionalization. First, the study is concerned with each of the factor's influence on the political decision-making process in the three country cases. Secondly, on country paired comparisons the findings for each of the countries are mutually contrasted. Although all identified factors seem to be at play with regard to flat-tax feasibility, I argue that it is either the strength or the weakness of labor unions' institutionalization and welfare identity that underlie the political decision-making in the East and the West and as a result determine the flat-tax (un-)feasibility. The absence of welfare identity in the East allows for higher coalition cohesion in favor and weaker opposition against the flattax adoption in contrast to the West.Series: Discussion Papers SFB International Tax Coordination
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Matulová, Andrea. "Komparace odvodového zatížení příjmů ze závislé činnosti a ze samostatné činnosti ve vybraných zemích." Master's thesis, Vysoká škola ekonomická v Praze, 2017. http://www.nusl.cz/ntk/nusl-360132.
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This thesis focuses on tax burden including social security contributions of employment and self-employment in selected countries as Czech Republic, Germany, United Kingdom and Canada. The aim of the thesis is to compare differences in taxation and social security contribution of employees and entrepreneurs. The first part of the thesis is focused on the main differences in taxation and social security contributions between selected countries, then each chapter is describing rules for tax and contributions calculation of employment and self-employment. In the end of the each chapter there are examples of tax burden including social security contributions of different tax payers with different incomes. And finally in the end of the thesis there is comparison of all selected countries. The results of analysis show that in all selected countries are entrepreneurs advantaged compared to employees and Czech Republic has the most significant differences in tax burden including social security contributions than other selected countries.
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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 with their "judge-made" law or whether the tax jurisdictions should be supporting a legislative route as opposed to a judicial one, in their efforts not only to combat tax avoidance but also to preserve taxpayer certainty. The question is whether the Doctrine of "Substance over Form" as applied by the judiciary is effective in combating tax avoidance, or whether a legislated general anti-avoidance provision is required. An intensive literature survey examines the changes which have occurred in the application of judicial tests from the 1930's to date and investigates the different approaches tax jurisdictions follow in order to combat tax avoidance. The effect of the introduction of anti-avoidance provisions in combating tax avoidance is evaluated by making a comparison between the United Kingdom and South Africa. [n the United Kingdom, the courts are relied on to create anti-tax avoidance rules, one of which is the Doctrine of "Substance over Form". The doctrine is very broad and identifies various applications of the doctrine, which have been developed by the courts. In South Africa, the Doctrine of "Substance over Form" has been applied in certain tax cases; however the South African Income Tax Act does include anti-tax avoidance sections aimed at specific tax avoidance schemes, as well as a general anti-tax avoidance measure enacted as section 103. The judicial tests have progressed and changed over time and the introduction of anti-avoidance legislation in the Income Tax Act has had an effect on tax planning opportunities. A distinction needs to be made between fraudulent and bona fide transactions while recognising the taxpayer's right to arrange his or her affairs in a manner which is beneficial to him or her from a tax perspective. Judicial activism and judicial legislation in the United Kingdom has created much uncertainty amongst taxpayers and as a result strongly supports the retention of a general anti-avoidance section within an Income Tax Act. A general anti-avoidance provision, following a legislative route, appears to be more consistent and effective in combating tax avoidance.
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Sloane, Justin. "A discussion and comparison of company legislation and tax legislation in South Africa, in relation to amalgamations and mergers." Thesis, Rhodes University, 2014. http://hdl.handle.net/10962/d1013028.
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In his 2012 Budget Review, the Minister of Finance, Pravin Gordhan acknowledged that the introduction of the "new" Companies Act had given rise to certain anomalies in relation to tax and subsequently announced that the South African government would undertake to review the nature of company mergers, acquisitions and other restructurings with the view of possibly amending the Income Tax Act and/or the "new" Companies Act, to bring the two legislations in line with one another. These anomalies give rise to the present research. The literature reviewed in the present research revealed and identified the inconsistencies that exist between the "new" Companies Act, 71 of 2008 and the Income Tax Act, 58 of 1962, specifically the inconsistencies that exist in respect of the newly introduced amalgamation or merger provisions as set out in the "new" Companies Act. Moreover, this research was undertaken to identify the potential tax implications insofar as they relate to amalgamation transactions and, in particular, the potential tax implications where such transactions, because of the anomalies, fall outside the ambit section 44 of the Income Tax Act, which would in normal circumstances provide for tax "rollover relief". In this regard, the present research identified the possible income tax, capital gains tax, value-added tax, transfer duty tax and securities transfer tax affected by an amalgamation transaction, on the assumption that the "rollover relief" in section 44 of the Income Tax Act does not apply.
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Hubáčková, Barbora. "Leasingové financování." Master's thesis, Vysoká škola ekonomická v Praze, 2008. http://www.nusl.cz/ntk/nusl-9273.
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The main theme of this diploma thesis is "Lease financing". The introduction is focused on some characteristic of the lease, the division and advantages, disadvantages and risks of lease. The diploma thesis deals with the legislative and taxation regulation of lease. So the other chapter concerns with the development of lease market in the Czech Republic. The last chapter includes the comparison between lease and loan calculated by net leasing advantage and discounted cost of lease and loan. The diploma thesis is supplemented with examples and charts.
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Reyneke, Danette. "An international taxation comparison of South African employees working abroad." Diss., 2012. http://hdl.handle.net/2263/22997.
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Human migration and the search for something better has been part of humankind’s existence for centuries. In today's world, migration is triggered by a variety of factors. One such factor is the influence of tax on the income of skilled employees. Although prior research has been performed to determine the influence of tax on employee migration, this research made use of complex formulae and did not focus on a South African point of view. This study aims to determine whether tax plays a role when a South African skilled worker decides to migrate to the United Kingdom (UK) or Australia with the intention of working there. The study compares the different income tax consequences of a South African resident working in South Africa versus the same South African resident working abroad. The comparison is done by analysing the income tax acts of the three different countries. The study attempts to establish the difference in tax consequences for a South African skilled employee migrating to the United Kingdom or Australia on a temporary versus a permanent basis. Examples are used to illustrate the different effects. Together with known statistics and the results of the illustrative examples, the study concluded that individuals in the United Kingdom and Australia, in most cases, pay less tax compared to individuals in South Africa. AFRIKAANS : Die migrasie van mense en die soeke na iets beters is reeds eeue lank deel van menswees. In die hedendaagse wêreld word menslike migrasie deur ʼn aantal faktore aangespoor. Een van hierdie faktore kan moontlik die impak van belasting op geskoolde werknemers wees. Alhoewel daar voorheen studies gedoen is oor die impak van belasting op werknemermigrasie, is sodanige studies deur middel van komplekse formules uitgevoer en het die fokuspunt nooit Suid-Afrikaanse werknemers ingesluit nie. Hierdie studie beoog om te bepaal of inkomstebelasting ʼn rol speel in die besluitnemingsproses van ʼn Suid-Afrikaanse werknemer wat verhuis na die Verenigde Koningryk of Australië. Om die doelwit te behaal sal die studie die verskillende belastinggevolge vergelyk van ʼn Suid-Afrikaanse inwoner wat in Suid-Afrika werksaam is versus dieselfde Suid-Afrikaanse inwoner werksaam in die buiteland. Die vergelyking word gedoen deur die verskillende inkomstebelastingwette van die drie lande te ontleed. Die studie gaan verder deur die verskillende belastingberekeninge vir ʼn Suid-Afrikaanse inwoner wat na die Verenigde Koningryk of Australië verhuis het op ʼn tydelike basis versus ʼn permanente basis uit te voer. Voorbeelde word gebruik om die verskillende gevolge te illustreer. Copyright 2011, University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria. Please cite as follows: Reyneke, D 2011, An international taxation comparison of South African employees working abroad, MCom dissertation, University of Pretoria, Pretoria, viewed yymmdd < http://upetd.up.ac.za/thesis/available/etd-03072012-165447 / > F12/4/155/gmDissertation (MCom)--University of Pretoria, 2012.
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Terhoeven, Janine. "The role of taxation in attracting foreign direct investments to South Africa : a BRICS comparison." Diss., 2012. http://hdl.handle.net/2263/23048.
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Foreign direct investment in South Africa is expected to increase economic growth thereby alleviating poverty. With technology offering a global trade arena it has become increasingly important for countries to compete for the attention of international investors. Through studies conducted to identify the matters international investors take into consideration in deciding where to invest, tax policies were identified as an area considered by foreign investors. Although research has been performed on the tax policies applied by countries and the effect thereof on foreign direct investment, limited attention has been afforded to the tax policies of South Africa. With its recent inclusion in BRICS, South Africa will be competing with these expected future economic giants. Determining whether South Africa’s tax policies are competitive with these countries would provide useful insight for the marketing of the country. The study discusses and compares the foreign direct investment determinants identified as having an impact on investors’ decisions in investing outside local borders before focusing on taxation in particular. Based on the literature reviewed and the comparison performed, the study concludes that South Africa’s tax policies are competitive with those offered by BRICS countries AFRIKAANS : Die verwagting is dat buitelandse direkte belegging in Suid-Afrika na ekonomiese groei sal lei en sodoende armoede verlig. Met tegnologie wat 'n globale handel arena aanbied, word dit al hoe belangriker vir lande om te kompeteer vir die aandag van internasionale beleggers. Deur middel van studies wat gedoen is om die aangeleenthede wat internasionale beleggers in ag neem en die besluit waar om te belê, te identifiseer, is die belastingbeleid geïdentifiseer as 'n gebied wat oorweeg word deur buitelandse beleggers. Hoewel navorsing uitgevoer is op die belastingbeleid wat toegepas word deur die lande en die uitwerking daarvan op buitelandse direkte belegging, is daar beperkte aandag verleen aan die belastingbeleid van Suid-Afrika. Met Suid-Afrika se onlangse opname in BRICS sal die land meeding met hierdie verwagte toekomstige ekonomiese reuse. Om vas te stel of Suid-Afrika se belastingbeleid mededingend is met hierdie lande, sal nuttige insig verskaf word vir die bemarking van die land. Die studie bespreek en vergelyk die buitelandse direkte belegging determinante wat verwag word om 'n uitwerking te hê op beleggers se besluite om te belê buite hul plaaslike grense voor daar gefokus word op belasting in die besonder. Op grond van die literatuur en die vergelyking uitgevoer, het die studie tot die gevolgtrekking gekom dat Suid-Afrika se belastingbeleid mededingend is met dié wat deur BRICS lande beskikbaar gemaak word. Copyright 2011, University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria. Please cite as follows: Terhoeven, J 2011, The role of taxation in attracting foreign direct investments to South Africa : a BRICS comparison, MCom dissertation, University of Pretoria, Pretoria, viewed yymmdd < http://upetd.up.ac.za/thesis/available/etd-03092012-122234 / > F12/4/168/gmDissertation (MCom)--University of Pretoria, 2012.
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Cushing, Tamara L. "A comparison of the relative reduction in land expectation value due to taxation of private forest land in the United States." 2006. http://purl.galileo.usg.edu/uga%5Fetd/cushing%5Ftamara%5Fl%5F200612%5Fphd.
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Marques, João Pedro da Costa Andrade. "Return on equity: a comparison between companies in Portugal and Brazil: similarities and differences." Master's thesis, 2012. http://hdl.handle.net/10362/16027.
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The purpose of this research is to study the Return on Equity of Portuguese and Brazilian companies, through the DuPont method. This project analyses whether differences in the ratios depend on specific features of the country, or if it is influenced by the industry where it is located. From the comparisons it is concluded that Brazilian companies pay higher corporate taxes and while the Portuguese companies are more leveraged, it is the Brazilian companies which pay higher interests. It is also noticeable that Portuguese companies take more advantage from the financing decisions and Brazilian on the investing decisions.
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Shtuk, Ekaterina. "In this research, we study the taxation of intangibles, particularly the intellectual property (IP) at the international level. The main issue is the comparison of IP tax incentives in the United Kingdom and the Russian Federation. We also investigated the importance of R&D and intangible assets for companies. International activity of corporations raises in some cases the problem of double non-taxation due to gaps in legislation. This leads to the erosion of the tax base and we analyse it in the context of the Base Erosion and Profit Shifting (BEPS) Action Plan issued by OECD. This plan contains recommendations for countries on avoiding tax evasion by taxpayers. From our comparasion we conclude that some features of British taxation for innovative companies can be introduced into Russian tax system. But first, it is necessary to resolve internal problems in Russian tax legislation." Master's thesis, 2018. http://hdl.handle.net/10316/84703.
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Dissertação de Mestrado em Economia apresentada à Faculdade de EconomiaComo Orientador do Trabalho de Projeto relativo ao Mestrado em Economia apresentado naFaculdade de Economia da Universidade de Coimbra, por Ekaterina Shtuk, intitulado "Incentivosfiscais aos ativos intangíveis: uma comparação entre o Reino Unido e a Federação Russa ", declaroque, na minha opinião, pode ser defendido perante um júri, em provas públicas.O Trabalho inclui as questões de investigação apropriadas na área do tratamento fiscal dapropriedade intelectual e, com base num método adequado, estende a análise e efetua umacomparação entre dois países economicamente relevantes.A mestranda desenvolveu um trabalho de avaliação das regras fiscais de incentivo à produção deintangíveis na Rússia e no Reino Unido, usando fontes legais e doutrinais, apresenta evidênciaempírica da utilização desses incentivos em ambos os países, e apresenta um contributo sobrequal pode ser o caminho da legislação russa na incorporação das atuais tendências sobre osincentivos mais eficazes à criação de propriedade intelectual.Dada a relevância dos intangíveis do crescimento e desenvolvimento económico, o tema afigura-se como bastante atual e pertinente para decisores políticos e empresariais. Adicionalmente,inclui-se na dissertação o impacto do Projeto “Base Erosion and Profit Shifting”, da Organizaçãopara Cooperação e Desenvolvimento Económico (OCDE) e da forma como tal projeto tenta evitarque os referidos incentivos sejam usados como forma de evasão fiscal. A Federação Russa poderáextrair de tais desenvolvimentos preciosos elementos para criação ou revisão de regimes fiscaisde apoio á investigação e desenvolvimento, cumprindo-se, assim, um objetivo importante destestrabalhos, que é o de propiciarem o cruzamento de experiências Internacionais em temáticaseconomicamente relevantes, como é o caso.
In this research, we study the taxation of intangibles, particularly the intellectual property (IP) at the international level. The main issue is the comparison of IP tax incentives in the United Kingdom and the Russian Federation. We also investigated the importance of R&D and intangible assets for companies. International activity of corporations raises in some cases the problem of double non-taxation due to gaps in legislation. This leads to the erosion of the tax base and we analyse it in the context of the Base Erosion and Profit Shifting (BEPS) Action Plan issued by OECD. This plan contains recommendations for countries on avoiding tax evasion by taxpayers. From our comparasion we conclude that some features of British taxation for innovative companies can be introduced into Russian tax system. But first, it is necessary to resolve internal problems in Russian tax legislation.The first issue is the review of the IP tax regime in the UK and identification of its strengths and weaknesses. The second issue is aimed at highlighting aspects that can be implemented in Russian tax legislation. Literature review gives a general description of the Intellectual property regime, its history and development. It also shows a brief presentation of the BEPS Action Plan, its main tasks and characteristics.The main body is devoted to the Action 5, that focus on IP taxation. This part describes the IP tax regime in the UK, and to the ways of stimulating innovations in Russia through the tax system. After the completion of the main analytical part, the work contains conclusions and recommendations for Russia and the possibilities for introducing the features of the British IP taxation into Russian legislation.