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Estian Haupt,Rudie Nel
AbstractOrientation: The South African tax legislation in respect of dividend cession.Research purpose: The objective of this article was to investigate the tax implications of a dividend cession for the cedent, cessionary and declaring company...
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Rudie Nel,Nicolette Klopper
AbstractOrientation: The tax deductibility of donations in kind in terms of the Income Tax Act No. 58 of 1962 in South Africa.Research purpose: The aim of this article is to critically analyse the provisions of section 18A(2)(a)(v) of...
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Estian Haupt,Rudie Nel
AbstractAn intuitive approach when considering the VAT implications of a dividend cession, which relates to a share, could be to classify it as a financial service and thus exempt from VAT. The fact that debt factoring, another cession transaction, has b...
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Rudie Nel,Andrea Herron
AbstractDebt reduction in business is recognised for the economic relief afforded to the debtor involved. The new debt reduction regime was introduced in the Income Tax Act (section 19 and paragraph 12A of the Eighth Schedule) with the aim of minimising ...
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Rudie Nel,Shene Steenkamp
AbstractThe location-independent nature of cloud-based transactions results in many source-related difficulties for normal tax purposes. This study considered the source determination for each of the possible classifications of cloud-based income (lease,...
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Shené Steenkamp,Rudie Nel
AbstractThe classification of income from cloud computing activities, according to the substance-over-form doctrine, is fundamental to the application of the correct taxation source test. The designation of IaaS, PaaS and SaaS, the three main cloud compu...
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Eduard Kilian,Rudie Nel
AbstractThe merchant cash advance is an emerging lending product designed to address the need to maintain cash flows and is essentially the business equivalent of a ?payday? loan. A lump-sum advance is made by the merchant cash advance service provider t...
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Mareli Dippenaar, Rudie Nel
The objective of the study was to determine the primary focus of selected developing countries (four BRICS countries; namely, Brazil, China, India and South Africa) in applying tax instruments to reduce their emissions from electricity generation. The fo...
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Linda van Schalkwyk,Rudie Nel
AbstractThe concept ?independent contractor? is one of the more contentious concepts contained in the Fourth Schedule to the Income Tax Act 58 of 1962, as amended. The classification of a person rendering services as either an ?employee? or an ?independe...
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