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Teses / dissertações sobre o tema "Tax law"

Autor: Grafiati

Publicado: 4 de junho de 2021

Última modificação: 25 de julho de 2025

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1

Pinto, Carlo. "Tax competition and EU law." [S.l. : Amsterdam : s.n.] ; Universiteit van Amsterdam [Host], 2002. http://dare.uva.nl/document/65841.

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2

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

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

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3

Nettestad, Malin. "Tax Treaties: The EU Tax Dilemma : - The relationship between EU State Aid and Tax Treaties." Thesis, Uppsala universitet, Juridiska institutionen, 2017. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-333798.

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4

Edwardes-Ker, Michael. "Tax treaty interpretation." Thesis, Queen Mary, University of London, 1994. http://qmro.qmul.ac.uk/xmlui/handle/123456789/1679.

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This thesis analyses which principles should govern the interpretation of tax treaties. This field is complex - because tax treaties have a dual status. Tax treaties are treaties between States - which are governed by public international law, the principles of which have been codified in the 1980 Vienna Convention on the Law of Treaties. Tax treaties are also laws which can affect the domestic rights of taxpayers (and States). Different, and possibly conflicting, principles of interpretation may apply in public international, and in (different) domestic, contexts. This thesis seeks to reconci

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5

Sotirova-Prodanova, Vessela. "Bulgarian Accountancy and Tax Law An Overview." WU Vienna University of Economics and Business, 2001. http://epub.wu.ac.at/3338/1/ap82.pdf.

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This commentary is purposed to provide a practical in-depth study of Bulgarian Accounting and Tax Legislation as of January 1, 2001. It considers the main accounting and reporting principles and the acts on which they are based. Special attention is devoted to the substantial compliance of Bulgarian accounting regulations with the international accounting standards and requirements. The commentary focuses on a relevantly detailed analysis of the Bulgarian Tax Legislation including the corporate and personal taxation, as well as the value-added tax and local taxes and fees. In this conne

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6

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

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7

Parmenion, Espeche Sebastián. "The Financial and Tax Law and its Relationship with Private Law." Derecho & Sociedad, 2015. http://repositorio.pucp.edu.pe/index/handle/123456789/118962.

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The purpose of this paper is to glimpse as the Tax Law is inserted in the unit of general law, being important for understanding the knowledge of public and private law in general.In the second part of the paper, the author analyzes how private law applies to the financial subsidiary way through forwarding making the tax law itself or by express provision of the civil. He emphasizes in this introduction as dogmatic construction of the tax liability, originated and rationale in civil liability.Finally the author explains how general principles of law necessarily apply to financial law. Thus, th

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8

Romano, Carlo. "Advance tax rulings and principles of law : towards a european tax rulings system? /." Amsterdam : IBFD, 2002. http://www.gbv.de/dms/spk/sbb/recht/toc/35816916X.pdf.

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9

Romano, Carlo Alberto. "Advance tax rulings and principles of law : towards a European tax rulings system? /." Amsterdam : IBFD, 2002. http://bibpurl.oclc.org/web/31193.

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10

GARUFI, SEBASTIANO. "International strategies on harmful tax competition: tax havens, soft law and sovereign states." Doctoral thesis, Università Bocconi, 2011. https://hdl.handle.net/11565/4054120.

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11

Cook, Dee M. "Rich law, poor law : differential response to tax and supplementary benefit fraud." Thesis, Keele University, 1988. http://eprints.keele.ac.uk/3570/.

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People who (in relation to their personal taxation) defraud the Inland Revenue and people who (in relation to their supplementary benefit payments) defraud the Department of Health and Social Security are similarly engaged in economic crimes which result in loss to the public purse. These crimes provoke differential political, official, judicial and public responses. Differential response to tax and supplementary benefit fraud can neither be explained by reference to qualitative differences in the commission of the illegal acts involved, nor by the crude suggestion that differential regulation

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12

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

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

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13

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

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

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14

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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15

De, Saude Stefanie Maria. "South African tax - for the expatriate." Thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/9173.

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Includes bibliographical references<br>Eisenberg de Saude inter alia assists and represents foreigners, corporates, non-resident companies and returning South Africans in their South African immigration affairs. Questions relating tax liability for the in respect of the aforementioned often arise during consultations/meetings/briefings. For this reason, I have decided to dedicate my research proposal to the aforementioned with the hope that it will equip me with sufficient knowledge to properly address and assist the foreign clients of Eisenberg de Saude in their tax uncertainties without gett

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16

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

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

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17

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

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

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18

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

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

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19

Muren, Gustaf, and Peter Krohn. "Tax Treaties and EC Law : Development, Problems and Solutions." Thesis, Jönköping University, JIBS, Commercial Law, 2008. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-1074.

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<p>Double taxation treaties play a vital part in the international relations between states</p><p>regarding taxation matters. Since double taxation can occur as soon as a person has</p><p>income in more than one state, it is very important that there can be effective remedies</p><p>to the problems that can occur in these situations. Double taxation treaties are</p><p>necessary in most situations created by international trade and they are even more</p><p>important in such a free flowing economic co-operation such as the EU, where the</p><p>trade between the Member States is not only free but a

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20

Loukota, Walter Stefaner Markus. "Taxation of artistes and sportsmen in international tax law /." [Vienna] : Wien : Postgraduate International Tax Law ; Linde, 2007. http://bvbr.bib-bvb.de:8991/F?func=service&doc_library=BVB01&doc_number=016135985&line_number=0001&func_code=DB_RECORDS&service_type=MEDIA.

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Theses (Master's)--Vienna University of Economics and Business Administration, 2007.<br>Collection of master's theses of the 2005/2007 postgraduate program "International Tax Law" at the Vienna University of Economics and Business Administration.

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21

Ugaz, Olivares Mauro, and Prentice Alejandra Alvarado. "Staff costs from the perspective of Labor Tax Law." THĒMIS-Revista de Derecho, 2014. http://repositorio.pucp.edu.pe/index/handle/123456789/109386.

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Nowadays, the extensive development ofTax Law has left no branch of Law to remindout of its influence, Labor Law not beingany exceptions. In fact, some Labor Law institutions such as remuneration and utilitiescan have important tributary consequences.Because of this link, the author, in the present article, makes a tributary analysis of Labor Law, reflecting on aspects related to personnelcosts and their tax implications.<br>En la actualidad, el amplio desarrollo que ha tenido el Derecho Tributario hace que no haya rama del Derecho que no se relacioneen algún punto con éste, no siendo el

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22

Du, Toit Leo. "Tax implications for business rescues in South African Law." Diss., University of Pretoria, 2012. http://hdl.handle.net/2263/26627.

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The South African Revenue Service has in the past had difficulty in applying debt forgiveness in cases of corporate and business rescues. Taxation legislation was drafted to counter innovative section 311 schemes of arrangements where the sole purpose was to obtain maximum taxations benefits in relation to entities in financial difficulties. This approach was only concerned with the interests of the Revenue authorities. The central theme of this study focuses of the procedures now available to tax authorities and debtors alike when compromises were and are considered in South Africa in terms o

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23

Tramontin, Marco <1994&gt. "Benford's Law and it's application to the tax declaration." Master's Degree Thesis, Università Ca' Foscari Venezia, 2019. http://hdl.handle.net/10579/14803.

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Benford’s Law, also referred to as the first digit Law, is somewhat of a counterintuitive law of nature that applies to numbers, more specifically to their distribution. Benford was not the only one to study such law, many mathematicians have attempted to understand the way numbers are distributed. Frank Benford, a physicist working for the Genereal Electric Company, made a very important observation by looking at the logarithmic tables. Such tables, were more consumed where the numbers had one as their first digit. Rather than just focusing on data, Benford also provided some very important e

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24

Righetto, Antonio <1994&gt. "The European State aid law and MNE's tax rulings." Master's Degree Thesis, Università Ca' Foscari Venezia, 2021. http://hdl.handle.net/10579/18874.

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La tesi prende in considerazione la disciplina Europea sugli aiuti di Stato dandone prima una descrizione generale, per poi prendere in esame dei casi recenti molto rilevanti per l'evoluzione della disciplina (Starbucks and Apple), analizzandone gli elementi che li costituiscono, le loro criticità e le relative sentenze del Tribunale Europeo traendo poi delle considerazioni finali.

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25

Keon, Ryan. "The Ottawa senators' lobby for comprehensive tax relief : a somewhat (but only somewhat) principled appeal to the notion of tax fairness." Thesis, McGill University, 2001. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=32808.

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The Ottawa Senators' lobby for comprehensive tax relief in favour of Canadian NHL teams towards the end of the 1990's is commendable. The argument that the Ottawa Senators hockey team is unfairly taxed in comparison to other Canadian businesses rejects reliance upon familiar economic impact studies of dubious validity, and is almost undeniably true in respect of property taxes. The argument is also colourable with respect to tax incentives which are given to businesses with links to Canadian culture and heritage, but are denied to professional hockey. Ultimately, however, the absence of any ne

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26

Durán, Rojo Luis Alberto. "The Transformation of modern law and its impact on the conception of Tax Law." IUS ET VERITAS, 2016. http://repositorio.pucp.edu.pe/index/handle/123456789/122411.

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This article analyzes the process of paradigm change in Law, a non-peaceful transition from a model developed in the XX century to a new law which will sit throughout the XXI century. The changes that have occurred from this new legal paradigm are not superficial, but rather crossing the structures and foundations of modern legal ideology and technique that underlies, as the constitutionalization of national law, the internationalization of economic relations, the development of treaties or development of Community law. Furthermore, the author refers to the impact that this change took place i

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27

Perakath, Aditya. "Brexit : Perspectives from the International Tax Paradigm." Thesis, Uppsala universitet, Juridiska institutionen, 2018. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-352338.

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28

Oliphant, Joel J. "Analysis of the positive tax law affecting First Nations in the context of Canadian tax policy." Thesis, National Library of Canada = Bibliothèque nationale du Canada, 2000. http://www.collectionscanada.ca/obj/s4/f2/dsk2/ftp03/MQ53118.pdf.

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29

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

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

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30

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

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

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31

Ruiz, de Castilla Ponce de León Francisco J., and Moreno Carmen Robles. "Constitutionalization of tax definition." Pontificia Universidad Católica del Perú, 2013. http://repositorio.pucp.edu.pe/index/handle/123456789/115642.

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The author works with the increasing constitutionalization process of Tax Law in the country as starting point; then, makes an analysis of tax concept evolution from a general tax law theory point of view. Afterwards, explains Tax Law Constitutionalization specifying main communicating vessels between Constitutional and Tax Law. Finally, highlights the most important values and goals related with taxing and constitutional control implementation by the Tax Court.<br>El autor toma como punto de partida el proceso de constitucionalización creciente del derecho tributario de nuestro país para lueg

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32

Schmoll, Moritz. "Broken promises : the politics of lax enforcement of tax laws in Egypt." Thesis, London School of Economics and Political Science (University of London), 2017. http://etheses.lse.ac.uk/3765/.

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This thesis seeks to explain the lax enforcement of tax laws in Egypt. While I acknowledge that existing explanations emphasising amongst other things the importance of low administrative capacity, neopatrimonialism, or rentseeking may discern some of the drivers of tax collection performance, I claim that other factors have been neglected. Based on a combination of historical and ethnographic research, I show how historical legacies and contemporary political dynamics intertwine and shape taxation at the three levels of microlevel tax relations, intra-bureaucratic relations, and the administr

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33

Medrano, Cornejo Humberto Félix, Rojo Luis Alberto Durán, and de Castilla Ponce Francisco Javier Ruiz. "Seminar: "Latest Tax Modifications"." Derecho & Sociedad, 2015. http://repositorio.pucp.edu.pe/index/handle/123456789/117547.

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The present seminar deals about the last modifications occurred in the Peruvian normativity on tax matter. This analysis focuses on the last modifications occurred on Income Tax, Tax Code, Tax Drawdown regime and Municipal Taxation.<br>El presente seminario versa sobre las últimas modificaciones ocurridas en la normatividad peruana en materia tributaria. Dicho análisis se centrará en las últimas modificaciones ocurridas en materia de Impuesto a la Renta, a nivel del Código Tributario, en el Régimen de Detracciones de Impuestos y en materia de Tributación Municipal.

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34

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

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

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35

Offermanns, René. "The entrepreneurship concept in a European comparative tax law perspective /." The Hague [u.a.] : Kluwer Law International, 2002. http://www.gbv.de/dms/spk/sbb/recht/toc/354069314.pdf.

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36

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

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37

Donayre, Lobo Gabriel. "The Legal Interpretation: Proposals for its Application in Tax Law." Derecho & Sociedad, 2015. http://repositorio.pucp.edu.pe/index/handle/123456789/118642.

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The first half of this report contains the concept of interpretation and its relationship with the written language. In addition, it proposes how the ambiguity of the language is one of the main problems for legal interpretation. The second half of this report establishes which components of the legal interpretation are, from a theoretical perspective –according to doctrine and practice– following jurisprudence, criteria and methods of interpretation allowed in Law. This part also proposes a route for the legal interpretation in Tax Law. The third part of this report contains the interpretatio

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38

Du, Toit Genevieve. "Estoppel and Substantive Legitimate Expectation in South African Tax Law." Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/4598.

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The purpose of this dissertation is to explore the legal avenues that may be open to taxpayers for holding the South African Revenue Services ('SARS') to the representations which it makes to the public in the form of general statements and specific rulings or directives. These avenues lie in two areas of law, namely the doctrine of estoppel as it has been developed in a public law context, and (potentially) the realm of so-called substantive legitimate expectation.

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

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

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40

Galle-From, Alex. "Death and Taxes : Analysis and Comparison of Bilateral International Succession TaxTreaty Structures Between the United States and Selected OECDStates." Thesis, Uppsala universitet, Juridiska institutionen, 2019. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-384696.

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41

Saruc, Naci Tolga. "The determinants of tax evasion : experiments with Turkish subjects." Thesis, University of Leicester, 2001. http://hdl.handle.net/2381/30137.

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This thesis explores the results of a series of tax experiments that were undertaken with various groups of people in Turkey in 1998. The experiments are described and their resulting data reported, following which conclusions and implications are reviewed.;In total 268 individuals successfully completed the experiments. The objective of the experiments was to gather information with which to test the effect of certain variables upon (i) the decision to evade income taxes and (ii) the amount of income tax to evade both in absolute terms and as a proportion of income.;Our results indicate a ver

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42

Lorish, Kathryn. "The Tax Exclusion for Employer-Sponsored Insurance and the Debate Over the Patient Protection and Affordable Care Act." Scholarship @ Claremont, 2012. http://scholarship.claremont.edu/cmc_theses/514.

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On March 23rd 2010, President Obama signed the Patient Protection and Affordable Care Act, setting in motion the most comprehensive health reform in the United States since 1965. Among many provisions within the near-3,000-page law, the Affordable Care Act (ACA) amends the Internal Revenue Code to include an excise tax on high cost employer-provided health plans. Starting in 2018, the new provision will levy a 40 percent tax on every dollar of health benefits received in excess of $10,200 for individuals and $27,500 for families. This provision alters tax policy dating back to 1954, and will s

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43

Parker, Mashooma. "A warning by press release that the retrospective application of legislation to completed transactions will be applied: A case analysis of the Pienaar Brothers (Pty) Ltd v Commissioner of the South African Revenue Services and Another (2017)." Master's thesis, Faculty of Law, 2018. http://hdl.handle.net/11427/30907.

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Pienaar Brothers (Pty) Ltd was an amalgamated company who sought to introduce a BEE element of ownership into its company in a tax efficient manner. Upon consulting their legal experts they were advised that the best manner in which they could achieve this objective was to enter into an amalgamation agreement in terms of section 44 of the ITA. At this particular time, the law was structured in a way in which it was possible to achieve this objective in a tax efficient matter, particularly because any distribution made by parties to the amalgamation transaction would be tax free. The problem ho

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44

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

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

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Deetlefs, David. "The deductibility of interest expenditure in leveraged buyout transactions under South African Income Tax Law : a critical examination of recent developments." Thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/12820.

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Includes bibliographical references.<br>The aims of this paper, are twofold: first, to provide an overview of the South African tax law principles governing the deductibility of interest expenditure incurred by taxpayers in respect of LBO transactions, as altered by the recent changes to the Act, and secondly, to critically consider and comment on the nature and perceived effect of such amendments.

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Ward, Grant. "Investing into africa: comparison between South African headquarter company and Mauritian GBC1 regime." Thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/9153.

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Includes bibliographical references.<br>In the 2010 Budget review The South African National Treasury announced it intended to create a business environment that would promote South Africa as a gateway to investment into Africa.1 As such a headquarter company regime would be considered. With globalisation and free movement of capital internationally countries are pursuing holding company regimes to attract investment to, and through, their shores. At the forefront are countries such as Belgium, Denmark, Luxemburg, Mauritius, the Netherlands, Singapore and the United Kingdom.2 Following the 201

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Johnson, Niel. "An analysis of the proposed annual mark-to-market taxation of the capital gains of long-term insurance policyholders." Thesis, University of Cape Town, 2013. http://hdl.handle.net/11427/4640.

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Includes bibliographical references.<br>This dissertation explores National Treasury's mark-to-market proposal which aims to tax the unrealised capital gains of long-term insurance policyholders on an annual basis. Although the proposal was ultimately rejected it remains under consideration. The mark-to-market proposal is evaluated against its intended purpose. The intended purpose is understood to be the collection by the South African Revenue Service (SARS) of capital gains tax (CGT) which has been 'effectively withheld' from policyholders by the insurer. Having gained an understanding of th

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

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

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Kabot, Guy Terence. "Purpose and effect: 'the role of a taxpayer's intention in tax legislation." Thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/9166.

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Includes bibliographical references<br>This paper examines the role of a taxpayer’s intention in the way certain transactions will be taxed. The paper will examine the weight accorded to a taxpayer’s stated intention in different situations (i.e. in what situations/ transactions will a taxpayer’s intention have comparatively little weight when compared to the objective facts of the case?) The paper first ascertains the meaning of intention/purpose/motive in terms of the Income Tax Act, 58 of 1962 as amended, (hereafter referred to as “the Act”). The question is whether these words are synonymo

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Huang, Shih-Chou, and 黃士洲. "Acceptance and Adjustment of Civil Law by Tax Laws." Thesis, 2007. http://ndltd.ncl.edu.tw/handle/03101080486646977873.

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博士<br>國立臺灣大學<br>法律學研究所<br>95<br>The topic of acceptance and adjustment of private laws by tax laws shall be deemed as norm conflict between tax laws and private laws, and it should be resovled under the harmonization of constitution. The method that constitution harmonizes the aforesaid norms conflict is to weigh the goals of tax laws against the fundamental right and order that private laws protect. During the weighing, the methodology of "Systemgerichtigkeit" can be adopted.

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