The distiction between debt and equity from an income tax perspective
- Authors: Duna, Nomfundo
- Date: 2020
- Subjects: Income tax -- South Africa
- Language: English
- Type: Thesis , Masters , MCOM
- Identifier: http://hdl.handle.net/10948/47791 , vital:40375
- Description: The debt bias gives rise to real and disadvantageous consequences for many jurisdictions. South Africa is by no means any safer from its dilutive and evasive effect. This bias in favour of debt arises as a result of the difference in the tax treatment of debt and equity which is found in the South African tax legislation. At the centre of the difference in tax treatment is that under the domestic tax legislation, interest incurred on debt is deductible to the extent that the debt was used to fund income generating assets which dividends payable to equity investors is not. From a South African perspective, the classification of a funding as debt or equity funding for tax purposes is not exhaustively dealt with within the tax legislation as it is not always that these terms are defined in the tax legislation. In some instances, common law is relied upon to classify funding as debt or equity funding. Furthermore, this classification and the resultant tax treatment of funding as either debt or equity becomes even more complicated when you consider the various tax avoidance mechanisms that taxpayer corporations use to take advantage of the debt bias. Tax avoidance mechanisms such as the uptake of excessive debt to increase interest deductions and the use of hybrid debt instruments has necessitated the inclusion of targeted anti-avoidance provisions that operate to either reclassify the nature of the funding or the return on such funding, or in some instances deny interest deductions. These targeted anti-avoidance provisions contain definitions of the type of funding that they apply to. In the South African context, the South African tax legislation contains provisions in respect of anti-excessive debt rules contained in section 23M and 23N as well as hybrid instruments contained in sections 8E,8EA, 8F and 8FA that aim to counter the extent to which taxpayers exploit the debt bias to avoid tax.
- Full Text:
- Date Issued: 2020
- Authors: Duna, Nomfundo
- Date: 2020
- Subjects: Income tax -- South Africa
- Language: English
- Type: Thesis , Masters , MCOM
- Identifier: http://hdl.handle.net/10948/47791 , vital:40375
- Description: The debt bias gives rise to real and disadvantageous consequences for many jurisdictions. South Africa is by no means any safer from its dilutive and evasive effect. This bias in favour of debt arises as a result of the difference in the tax treatment of debt and equity which is found in the South African tax legislation. At the centre of the difference in tax treatment is that under the domestic tax legislation, interest incurred on debt is deductible to the extent that the debt was used to fund income generating assets which dividends payable to equity investors is not. From a South African perspective, the classification of a funding as debt or equity funding for tax purposes is not exhaustively dealt with within the tax legislation as it is not always that these terms are defined in the tax legislation. In some instances, common law is relied upon to classify funding as debt or equity funding. Furthermore, this classification and the resultant tax treatment of funding as either debt or equity becomes even more complicated when you consider the various tax avoidance mechanisms that taxpayer corporations use to take advantage of the debt bias. Tax avoidance mechanisms such as the uptake of excessive debt to increase interest deductions and the use of hybrid debt instruments has necessitated the inclusion of targeted anti-avoidance provisions that operate to either reclassify the nature of the funding or the return on such funding, or in some instances deny interest deductions. These targeted anti-avoidance provisions contain definitions of the type of funding that they apply to. In the South African context, the South African tax legislation contains provisions in respect of anti-excessive debt rules contained in section 23M and 23N as well as hybrid instruments contained in sections 8E,8EA, 8F and 8FA that aim to counter the extent to which taxpayers exploit the debt bias to avoid tax.
- Full Text:
- Date Issued: 2020
A qualitative investigation of gendered perspectives on, maternity leave/family responsibility duties/social roles and access to career development, in the Johannesburg branch of a Multination Corporation (MNC): the case of company A, S.A. Johannesburg branch
- Authors: Mbatha, Mbalenhle
- Date: 2012
- Subjects: Glass ceiling (Employment discrimination) -- South Africa -- Johannesburg , Sex role in the work environment -- South Africa -- Johannesburg
- Language: English
- Type: Thesis , Masters , MA
- Identifier: http://hdl.handle.net/10948/5657 , vital:20956
- Description: In recent years, there has been increasing concern that gender bias has prevented women from advancing as rapidly and as frequently as men into management positions. Although the number of women managers has increased, they may experience difficulty moving into upper management positions. The purpose of our research was to study employee gender perception of key variables of women and the positions held in high technology companies. In this research, phenomenological research method was chosen, because the aim of it is to determine what the experience means for the people who have experienced it. Based on the collected data, answers and experiences, structural analysis was done in order to find out the major phenomena of gender perceptions. A number of variables uncover the perception of aspects of policy and gender and barriers that may affect female employees' opportunities for advancement. Using a sample of 30 full-time employees from Company A, the results indicated that position held was significantly different for male and female employees. The results also indicated that neither male nor female employees appeared to notice the apparent perceptions apparently as a glass ceiling within their company and the Implications discussed and recommendations provided. With reference to the Empirical research, this paper increases the knowledge about women’s career development and provides recommendations how to deal with it. It is also expected that this thesis will be helpful to all women who are in the labour market for their career development and advancement.
- Full Text:
- Date Issued: 2012
- Authors: Mbatha, Mbalenhle
- Date: 2012
- Subjects: Glass ceiling (Employment discrimination) -- South Africa -- Johannesburg , Sex role in the work environment -- South Africa -- Johannesburg
- Language: English
- Type: Thesis , Masters , MA
- Identifier: http://hdl.handle.net/10948/5657 , vital:20956
- Description: In recent years, there has been increasing concern that gender bias has prevented women from advancing as rapidly and as frequently as men into management positions. Although the number of women managers has increased, they may experience difficulty moving into upper management positions. The purpose of our research was to study employee gender perception of key variables of women and the positions held in high technology companies. In this research, phenomenological research method was chosen, because the aim of it is to determine what the experience means for the people who have experienced it. Based on the collected data, answers and experiences, structural analysis was done in order to find out the major phenomena of gender perceptions. A number of variables uncover the perception of aspects of policy and gender and barriers that may affect female employees' opportunities for advancement. Using a sample of 30 full-time employees from Company A, the results indicated that position held was significantly different for male and female employees. The results also indicated that neither male nor female employees appeared to notice the apparent perceptions apparently as a glass ceiling within their company and the Implications discussed and recommendations provided. With reference to the Empirical research, this paper increases the knowledge about women’s career development and provides recommendations how to deal with it. It is also expected that this thesis will be helpful to all women who are in the labour market for their career development and advancement.
- Full Text:
- Date Issued: 2012
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