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Lee-Ann Steenkamp
AbstractMost tax treaties (including South Africa
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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,Peter Cramer
AbstractThe South African Revenue Service (SARS) implemented a more aggressive reporting system in 2008 by introducing new reportable arrangements ('RA') provisions in the Income Tax Act. In March 2010, SARS issued a revised Draft Guide to Reportable Arr...
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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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Lee-Ann Steenkamp,Peter Cramer
AbstractThe reportable arrangements (RA) provisions are contained in sections 80M to 80T of the Income Tax Act. SARS issued a revised Draft Guide on 31 March 2010, which contains a model for the application of these provisions. However, due to numerous d...
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