A critical analysis of the income tax implications of persons ceasing to be a resident of South Africa
- Authors: Loyson, Richard Michael
- Date: 2010
- Subjects: Income tax -- South Africa , Double taxation -- South Africa , Aliens -- Taxation -- South Africa , Capital gains tax -- South Africa , Citizenship -- South Africa , Emigration and immigration law -- South Africa
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: vital:8957 , http://hdl.handle.net/10948/1180 , Income tax -- South Africa , Double taxation -- South Africa , Aliens -- Taxation -- South Africa , Capital gains tax -- South Africa , Citizenship -- South Africa , Emigration and immigration law -- South Africa
- Description: Over the last 10 years the South African fiscus has introduced numerous changes to the Income Tax Act (ITA) which affect the income tax implications of persons ceasing to be a resident of South Africa. The two main changes were: - The introduction of a world-wide basis of taxation for residents - The introduction of capital gains tax (CGT) as part of the ITA The aim of this treatise was to identify the income tax implications of persons ceasing to be a resident of South Africa. Resulting from this research, several issues in the ITA have been identified, and the two major ones are summarised below. Firstly, upon the emigration of the taxpayer, there is a deemed disposal of a taxpayer’s assets in terms of paragraph 12 of the Eighth Schedule. It is submitted that the resulting exit tax may be unconstitutional for individuals. It is recommended that South Africa should adopt the deferral method within its domestic legislation for individuals who are emigrating. The deferral method postpones the liability until the disposal of the asset. Secondly, on the subsequent disposal of assets by former residents where there was no exit charge in terms of the exemption under paragraph 12(2)(a)(i) of the Eighth Schedule. Depending on the specific double tax agreement (DTA) that has been entered into with the foreign country, taxpayers have been given vii the opportunity to minimise or eliminate the tax liability with regard to certain assets. This should be of concern from the point of view of the South African government. Further issues noted in this treatise were the following: - It is submitted that the term ‘place of effective management’ has been incorrectly interpreted by SARS in Interpretation Note 6. - It is further submitted that the interpretation by SARS of paragraph 2(2) of the Eighth Schedule is technically incorrect. The above issues that have been identified present opportunities to emigrants to take advantage of the current tax legislation. It is further recommended that taxpayers who are emigrating need to consider the South African domestic tax law implications, respective DTA’s, as well as the domestic tax laws of the other jurisdiction, not only on the date of emigration but also on the subsequent disposal of the respective assets.
- Full Text:
- Date Issued: 2010
- Authors: Loyson, Richard Michael
- Date: 2010
- Subjects: Income tax -- South Africa , Double taxation -- South Africa , Aliens -- Taxation -- South Africa , Capital gains tax -- South Africa , Citizenship -- South Africa , Emigration and immigration law -- South Africa
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: vital:8957 , http://hdl.handle.net/10948/1180 , Income tax -- South Africa , Double taxation -- South Africa , Aliens -- Taxation -- South Africa , Capital gains tax -- South Africa , Citizenship -- South Africa , Emigration and immigration law -- South Africa
- Description: Over the last 10 years the South African fiscus has introduced numerous changes to the Income Tax Act (ITA) which affect the income tax implications of persons ceasing to be a resident of South Africa. The two main changes were: - The introduction of a world-wide basis of taxation for residents - The introduction of capital gains tax (CGT) as part of the ITA The aim of this treatise was to identify the income tax implications of persons ceasing to be a resident of South Africa. Resulting from this research, several issues in the ITA have been identified, and the two major ones are summarised below. Firstly, upon the emigration of the taxpayer, there is a deemed disposal of a taxpayer’s assets in terms of paragraph 12 of the Eighth Schedule. It is submitted that the resulting exit tax may be unconstitutional for individuals. It is recommended that South Africa should adopt the deferral method within its domestic legislation for individuals who are emigrating. The deferral method postpones the liability until the disposal of the asset. Secondly, on the subsequent disposal of assets by former residents where there was no exit charge in terms of the exemption under paragraph 12(2)(a)(i) of the Eighth Schedule. Depending on the specific double tax agreement (DTA) that has been entered into with the foreign country, taxpayers have been given vii the opportunity to minimise or eliminate the tax liability with regard to certain assets. This should be of concern from the point of view of the South African government. Further issues noted in this treatise were the following: - It is submitted that the term ‘place of effective management’ has been incorrectly interpreted by SARS in Interpretation Note 6. - It is further submitted that the interpretation by SARS of paragraph 2(2) of the Eighth Schedule is technically incorrect. The above issues that have been identified present opportunities to emigrants to take advantage of the current tax legislation. It is further recommended that taxpayers who are emigrating need to consider the South African domestic tax law implications, respective DTA’s, as well as the domestic tax laws of the other jurisdiction, not only on the date of emigration but also on the subsequent disposal of the respective assets.
- Full Text:
- Date Issued: 2010
An evaluation of the performance management and development system at the Department of Safety and Liaison in the Eastern Cape
- Authors: Menemene, Nonkosi Arnoria
- Date: 2015
- Subjects: Performance -- Management -- Evaluation Performance -- Management Employees -- Rating of
- Language: English
- Type: Thesis , Masters , MA
- Identifier: http://hdl.handle.net/10948/9875 , vital:26629
- Description: The performance management and development system (PMDS) is a tool that is used by government to measure the performance of individuals in the organisation. PMDS was developmental in its nature in identifying the development of employees and training in case of poor performance. The main aim of the PMDS is to motivate officials in the organisation by rewarding a performance bonus at the end of the financial year. There are challenges that affect the PMDS: officials felt that the system did not motivate them; it is perceived as a 14th cheque and some of them felt the system should be terminated. The main aim of the study is to evaluate the performance management and development system at the Department of Safety and Liaison in the Eastern Cape. Quantitative and qualitative data was collected through questionnaires and interviews. Questionnaires were distributed to officials from levels 1 - 8 and interviews were conducted with assistant managers, managers and senior managers. Descriptive statistics were used to analyse the questionnaires and transcriptions were used to interpret the interviews. The results of the study reflect that most officials in the Department are young and new to the public service. The findings show that the employees of the Department are average in their performance and the Department perceives that the PMDS is not used to identify poor performance and training. The system is not implemented effectively and efficiently. Based on the findings and recommendations made to management to facilitate the training on PMDS and also to allow the processes and procedures to be more efficient. Furthermore allowing performance from all staff to achieve the core objectives of the department.
- Full Text:
- Date Issued: 2015
- Authors: Menemene, Nonkosi Arnoria
- Date: 2015
- Subjects: Performance -- Management -- Evaluation Performance -- Management Employees -- Rating of
- Language: English
- Type: Thesis , Masters , MA
- Identifier: http://hdl.handle.net/10948/9875 , vital:26629
- Description: The performance management and development system (PMDS) is a tool that is used by government to measure the performance of individuals in the organisation. PMDS was developmental in its nature in identifying the development of employees and training in case of poor performance. The main aim of the PMDS is to motivate officials in the organisation by rewarding a performance bonus at the end of the financial year. There are challenges that affect the PMDS: officials felt that the system did not motivate them; it is perceived as a 14th cheque and some of them felt the system should be terminated. The main aim of the study is to evaluate the performance management and development system at the Department of Safety and Liaison in the Eastern Cape. Quantitative and qualitative data was collected through questionnaires and interviews. Questionnaires were distributed to officials from levels 1 - 8 and interviews were conducted with assistant managers, managers and senior managers. Descriptive statistics were used to analyse the questionnaires and transcriptions were used to interpret the interviews. The results of the study reflect that most officials in the Department are young and new to the public service. The findings show that the employees of the Department are average in their performance and the Department perceives that the PMDS is not used to identify poor performance and training. The system is not implemented effectively and efficiently. Based on the findings and recommendations made to management to facilitate the training on PMDS and also to allow the processes and procedures to be more efficient. Furthermore allowing performance from all staff to achieve the core objectives of the department.
- Full Text:
- Date Issued: 2015
Assessing the municipal performance management system on service delivery : the case of Lukhanji Municipality
- Authors: Bam, Liseka Lindelwa
- Date: 2013
- Subjects: Performance -- Management , Local officials and employees -- South Africa -- Queenstown , Employees -- Rating of -- South Africa -- Queenstown , Public administration -- South Africa -- Queenstown , Local government -- South Africa -- Queenstown
- Language: English
- Type: Thesis , Masters , MPA
- Identifier: vital:8319 , http://hdl.handle.net/10948/d1020140
- Description: The performance management system has been introduced in the South African public service with the intensions of monitoring, reviewing, assessing performance, developing underperformers and recognising and rewarding good performance. This study was undertaken as an attempt to assess whether the Lukhanji municipality performance management systems contribute to the improvement of service delivery and employee productivity. The literature review undertaken in this study, shows that there is a general poor understanding of performance management systems in Lukhanji municipality. The literature review further establishes that there are several challenges that hinder the effective implementation of a performance management system in the municipality. Other findings of the study include that there is a challenge in setting the unrealistic performance targets which are unrealisable by employees. These are the reasons why productivity levels are not always realised and targets not achieved by Lukhanji municipality. The main findings of the study are that, although performance management systems play a significant role in the improvement of service delivery, it has not contributed in the improvement of employee productivity of the Lukhanji municipality. The main recommendation on the basis of this finding is that there should be thorough and regular training of officials within the Lukhanji Municipality about the performance management system and how it influences productivity and service delivery. In conclusion, the Municipal Executive Mayoral Committee should demand verifiable evidence to justify a higher rating during quarterly assessments, and that punitive disciplinary measures be taken against those who do not comply with the provision of the performance management system framework, particularly failure to submit performance instruments.
- Full Text:
- Date Issued: 2013
- Authors: Bam, Liseka Lindelwa
- Date: 2013
- Subjects: Performance -- Management , Local officials and employees -- South Africa -- Queenstown , Employees -- Rating of -- South Africa -- Queenstown , Public administration -- South Africa -- Queenstown , Local government -- South Africa -- Queenstown
- Language: English
- Type: Thesis , Masters , MPA
- Identifier: vital:8319 , http://hdl.handle.net/10948/d1020140
- Description: The performance management system has been introduced in the South African public service with the intensions of monitoring, reviewing, assessing performance, developing underperformers and recognising and rewarding good performance. This study was undertaken as an attempt to assess whether the Lukhanji municipality performance management systems contribute to the improvement of service delivery and employee productivity. The literature review undertaken in this study, shows that there is a general poor understanding of performance management systems in Lukhanji municipality. The literature review further establishes that there are several challenges that hinder the effective implementation of a performance management system in the municipality. Other findings of the study include that there is a challenge in setting the unrealistic performance targets which are unrealisable by employees. These are the reasons why productivity levels are not always realised and targets not achieved by Lukhanji municipality. The main findings of the study are that, although performance management systems play a significant role in the improvement of service delivery, it has not contributed in the improvement of employee productivity of the Lukhanji municipality. The main recommendation on the basis of this finding is that there should be thorough and regular training of officials within the Lukhanji Municipality about the performance management system and how it influences productivity and service delivery. In conclusion, the Municipal Executive Mayoral Committee should demand verifiable evidence to justify a higher rating during quarterly assessments, and that punitive disciplinary measures be taken against those who do not comply with the provision of the performance management system framework, particularly failure to submit performance instruments.
- Full Text:
- Date Issued: 2013
Discrepancy in conventional microscopic manual differential counts of band neutrophils among microscopists
- Godson-Katchew, Chesna Terry-Lee
- Authors: Godson-Katchew, Chesna Terry-Lee
- Date: 2018
- Subjects: Neutrophils , Hematology Medical statistics -- Research
- Language: English
- Type: Thesis , Masters , MHSc
- Identifier: http://hdl.handle.net/10948/30127 , vital:30830
- Description: The interpretation of the band neutrophil count on manual differential counts performed amongst microscopists can vary greatly. The band neutrophil is an immature granulocyte, maturing towards a segmented neutrophil. There are varying degrees of misconception of the band neutrophil identification, as the band neutrophil closely resembles the maturing segmented neutrophil. Although there are guidelines for the identification of band neutrophils, many laboratories incorporate their own “standard” as to what a band neutrophil should look like. Even when a standard exists for the identification of band neutrophils, many microscopists still have difficulty identifying these cells, making it difficult to accurately perform, interpret and report a manual differential count. Due to the controversy it is thus necessary to identify whether the problem lies with the identification of the band neutrophil itself, or the individual microscopist’s perception of differentiation between the band neutrophil and a maturing segmented neutrophil. The purpose of this study was to establish the accuracy by which microscopists distinguish band neutrophils from mature segmented neutrophils, the extent of discrepancies in the band neutrophil count amongst microscopists, to establish whether microscopists required re-training and to establish meaningful recommendations for microscopists to aid in the accurate identification of band neutrophils. The researcher thus made use of a self-administered picture diagram, distributed among microscopists to assess the accuracy of the band neutrophil counts prior to training. Participants counted an average of 61.47% neutrophils and 38.53% band neutrophils. Coefficient of variation (CV) for neutrophils and band neutrophils were calculated and yielded a CV of 22.48 and 35.87 respectively. Due to the high CV calculated, suggesting a greater level of dispersion around the mean, the researcher investigated individual responses from the picture-diagram. With the findings of the individual picture-diagram results, the researcher developed an impression that there was a large variation in counts for both neutrophils and band cells. Training was then given to participants arranged by the researcher, for accurate band neutrophil identification. Following training a second survey was conducted in order to assess the variation in counts among microscopists. 1 The peripheral blood smear was then provided and used to perform a manual differential count by conventional light microscopy, in order to compare results. Similarly, results obtained by the microscopists was compared to the verified manual differential count performed by a Haematologist; to improve the accuracy of results reported routinely. With the findings of the individual manual differential count results the researcher observed, that there was indeed a discrepancy in the manual differential counts performed by microscopists.
- Full Text:
- Date Issued: 2018
- Authors: Godson-Katchew, Chesna Terry-Lee
- Date: 2018
- Subjects: Neutrophils , Hematology Medical statistics -- Research
- Language: English
- Type: Thesis , Masters , MHSc
- Identifier: http://hdl.handle.net/10948/30127 , vital:30830
- Description: The interpretation of the band neutrophil count on manual differential counts performed amongst microscopists can vary greatly. The band neutrophil is an immature granulocyte, maturing towards a segmented neutrophil. There are varying degrees of misconception of the band neutrophil identification, as the band neutrophil closely resembles the maturing segmented neutrophil. Although there are guidelines for the identification of band neutrophils, many laboratories incorporate their own “standard” as to what a band neutrophil should look like. Even when a standard exists for the identification of band neutrophils, many microscopists still have difficulty identifying these cells, making it difficult to accurately perform, interpret and report a manual differential count. Due to the controversy it is thus necessary to identify whether the problem lies with the identification of the band neutrophil itself, or the individual microscopist’s perception of differentiation between the band neutrophil and a maturing segmented neutrophil. The purpose of this study was to establish the accuracy by which microscopists distinguish band neutrophils from mature segmented neutrophils, the extent of discrepancies in the band neutrophil count amongst microscopists, to establish whether microscopists required re-training and to establish meaningful recommendations for microscopists to aid in the accurate identification of band neutrophils. The researcher thus made use of a self-administered picture diagram, distributed among microscopists to assess the accuracy of the band neutrophil counts prior to training. Participants counted an average of 61.47% neutrophils and 38.53% band neutrophils. Coefficient of variation (CV) for neutrophils and band neutrophils were calculated and yielded a CV of 22.48 and 35.87 respectively. Due to the high CV calculated, suggesting a greater level of dispersion around the mean, the researcher investigated individual responses from the picture-diagram. With the findings of the individual picture-diagram results, the researcher developed an impression that there was a large variation in counts for both neutrophils and band cells. Training was then given to participants arranged by the researcher, for accurate band neutrophil identification. Following training a second survey was conducted in order to assess the variation in counts among microscopists. 1 The peripheral blood smear was then provided and used to perform a manual differential count by conventional light microscopy, in order to compare results. Similarly, results obtained by the microscopists was compared to the verified manual differential count performed by a Haematologist; to improve the accuracy of results reported routinely. With the findings of the individual manual differential count results the researcher observed, that there was indeed a discrepancy in the manual differential counts performed by microscopists.
- Full Text:
- Date Issued: 2018
The influence of genetic relatedness on sociality and demography of female African elephants
- Authors: Munishi, Linus Kasian
- Date: 2011
- Subjects: African elephant , Wildlife conservation , Elephants -- Africa
- Language: English
- Type: Thesis , Doctoral , DPhil
- Identifier: vital:10711 , http://hdl.handle.net/10948/d1011612 , African elephant , Wildlife conservation , Elephants -- Africa
- Description: Many elephant populations across Africa were or are being devastated by poaching and habitat loss, making population and range size for the species important issues of conservation concern in elephant ranging areas, including Tarangire National Park (TNP). Poaching and/or overhunting are known to have direct effects on the demography of elephant populations. The current understanding of the indirect effects of poaching on the sociality and demography of elephant populations is relatively poor, both at the group and an individual level. In this thesis the importance of genetic relatedness (as influenced by poaching) on sociality and demography of the female elephants was studied, using a combination of genetic, observation of behaviour and two decades of demography data collected from the northern subpopulation of TNP. I investigated and characterized the relatedness categories within elephant groups. Using a conceptual model for group size analysis in aggregation economies, I hypothesized that elephant populations subject to social disruptions due to poaching would exhibit characteristics of the free entry model, whereas more stable, closed populations would better fit the group-controlled model. I present a rare quantitative analysis of genetic relatedness and group size patterns among groups of adult female elephants in two wild populations: one in Tarangire National Park (TNP), Tanzania, and another in Addo Elephant National Park (AENP), South Africa. I demonstrate that the group size in African elephant populations is governed by genetic relatedness, and that poaching/overhunting has a significant influence upon the apparent group formation and size in elephants. I then focused on the effect of relatedness on agonistic interactions between adult females. I hypothesized that individual-based aggressive interactions among adult female African elephants would vary according to degree of kinship, with closely related dyads showing less aggression towards each other in resource-limited environments, thereby leading to indirect fitness benefits for individuals. As predicted, females did not show agonistic interactions to their close kin most often, and the frequency and intensity of aggressive interactions was inversely related to the degree of relatedness of the interactants. The effect of group relatedness and structure on reproductive success of individual female African elephant in TNP was also investigated. Adult female reproductive success was significantly influenced by within- group relatedness and structure. Higher reproductive success (with higher frequency of calf production and survival and more female calves produced) were more evident in the closely related groups than groups with low relatedness, suggesting that females from genetically disrupted groups are less likely to be reproductive than those in closely related groups. The possibility of negative effects of poaching on the subsequent generation of poached adult females and the alternative of a positive demographic response through reduced density was assessed by analysing the demographic patterns of the first generation (F1) females of prime-aged adult female African elephants in TNP using within- group relatedness and size. I also compared vital rate (age of first birth and interbirth interval) responses of first generation (F1) cows from Tarangire (poached) elephants with other females from poached (Northern Luangwa National Park, Zambia) and unpoached (Amboseli National Park, Kenya and Addo Elephant National Park, South Africa) populations. Group relatedness had no significant effect on sex ratio of the F1 cows‟ calves. There was a significant difference between the mean age of first birth and interbirth interval of F1 cows from the two (poached, Tarangire and unpoached, Amboseli National Park) elephant populations, suggesting that elephant populations reduced by poaching to low levels show an increase vigour through release from density constraints. Based on these results, the broader implications of secondary effects of poaching on elephant populations are critically evaluated. Also the importance of understanding the consequences of these effects is highlighted in light of other elephant conservation and management approaches. This understanding is useful in making conservation and management decisions for elephants and other biodiversity.
- Full Text:
- Date Issued: 2011
- Authors: Munishi, Linus Kasian
- Date: 2011
- Subjects: African elephant , Wildlife conservation , Elephants -- Africa
- Language: English
- Type: Thesis , Doctoral , DPhil
- Identifier: vital:10711 , http://hdl.handle.net/10948/d1011612 , African elephant , Wildlife conservation , Elephants -- Africa
- Description: Many elephant populations across Africa were or are being devastated by poaching and habitat loss, making population and range size for the species important issues of conservation concern in elephant ranging areas, including Tarangire National Park (TNP). Poaching and/or overhunting are known to have direct effects on the demography of elephant populations. The current understanding of the indirect effects of poaching on the sociality and demography of elephant populations is relatively poor, both at the group and an individual level. In this thesis the importance of genetic relatedness (as influenced by poaching) on sociality and demography of the female elephants was studied, using a combination of genetic, observation of behaviour and two decades of demography data collected from the northern subpopulation of TNP. I investigated and characterized the relatedness categories within elephant groups. Using a conceptual model for group size analysis in aggregation economies, I hypothesized that elephant populations subject to social disruptions due to poaching would exhibit characteristics of the free entry model, whereas more stable, closed populations would better fit the group-controlled model. I present a rare quantitative analysis of genetic relatedness and group size patterns among groups of adult female elephants in two wild populations: one in Tarangire National Park (TNP), Tanzania, and another in Addo Elephant National Park (AENP), South Africa. I demonstrate that the group size in African elephant populations is governed by genetic relatedness, and that poaching/overhunting has a significant influence upon the apparent group formation and size in elephants. I then focused on the effect of relatedness on agonistic interactions between adult females. I hypothesized that individual-based aggressive interactions among adult female African elephants would vary according to degree of kinship, with closely related dyads showing less aggression towards each other in resource-limited environments, thereby leading to indirect fitness benefits for individuals. As predicted, females did not show agonistic interactions to their close kin most often, and the frequency and intensity of aggressive interactions was inversely related to the degree of relatedness of the interactants. The effect of group relatedness and structure on reproductive success of individual female African elephant in TNP was also investigated. Adult female reproductive success was significantly influenced by within- group relatedness and structure. Higher reproductive success (with higher frequency of calf production and survival and more female calves produced) were more evident in the closely related groups than groups with low relatedness, suggesting that females from genetically disrupted groups are less likely to be reproductive than those in closely related groups. The possibility of negative effects of poaching on the subsequent generation of poached adult females and the alternative of a positive demographic response through reduced density was assessed by analysing the demographic patterns of the first generation (F1) females of prime-aged adult female African elephants in TNP using within- group relatedness and size. I also compared vital rate (age of first birth and interbirth interval) responses of first generation (F1) cows from Tarangire (poached) elephants with other females from poached (Northern Luangwa National Park, Zambia) and unpoached (Amboseli National Park, Kenya and Addo Elephant National Park, South Africa) populations. Group relatedness had no significant effect on sex ratio of the F1 cows‟ calves. There was a significant difference between the mean age of first birth and interbirth interval of F1 cows from the two (poached, Tarangire and unpoached, Amboseli National Park) elephant populations, suggesting that elephant populations reduced by poaching to low levels show an increase vigour through release from density constraints. Based on these results, the broader implications of secondary effects of poaching on elephant populations are critically evaluated. Also the importance of understanding the consequences of these effects is highlighted in light of other elephant conservation and management approaches. This understanding is useful in making conservation and management decisions for elephants and other biodiversity.
- Full Text:
- Date Issued: 2011
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