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Muhammad Rifky Santoso
Pág. 1 - 12
The tax authority performs tax audits to increase revenue and ensure that taxpayers carry out their tax obligations properly. During the tax audit, there could be a dispute between the taxpayers and the tax authority in interpreting the tax treaty. This ...
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Lee-Ann Steenkamp
AbstractMost tax treaties (including South Africa's) are based on the OECD Model Tax Convention on Income and Capital and the related Commentary (the 'OECD Model'). Notwithstanding the uncertainty surrounding its legal status, the courts in many countrie...
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Lee-Ann Steenkamp
AbstractMost tax treaties (including South Africa
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Lee-Ann Steenkamp
In this era of globalisation, developing countries have resorted to double tax agreements in order to attract foreign direct investment. The extent to which a countrys tax treaty policy favours developing countries or not depends upon the extent to which...
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David Costa,Lilla Stack
AbstractThis article investigates the legal status of Double Taxation Agreements, and the relationship between Double Taxation Agreements, which are concluded in terms of section 108 of the Income Tax Act, and the provisions of the Income Tax Act (taking...
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