Base erosion and profit shifting by multinational corporations and weaknesses revealed in South African income tax legislation
- Authors: Peerbhai, Aneesa
- Date: 2015
- Subjects: International business enterprises -- Law and legislation -- South Africa , Corporations -- Taxation -- Law and legislation -- South Africa , Tax planning -- South Africa
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: vital:917 , http://hdl.handle.net/10962/d1017540
- Description: This research examined the concept of base erosion and profit shifting in the context of tax schemes employed by multinational corporations. The objective of this thesis was to identify weaknesses within South Africa’s income tax legislation, based on these schemes, and further to propose recommendations to counter the occurrence of base erosion and profit shifting by multinational companies. The research also comprised of a limited review of current global and South African initiatives to address the problem of base erosion and profit shifting. It was concluded that there are a number of weaknesses in the definitions and provisions of the South African income tax legislation that need to be addressed in order to reduce base erosion and profit shifting. Brief recommendations were proposed in relation to each of the weaknesses, in order to address them.
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- Date Issued: 2015
Financial liberalization, financial development and economic growth: the case for South Africa
- Authors: Savanhu, Tatenda
- Date: 2012
- Subjects: Economic development -- Case studies -- South Africa Principal components analysis Econometric models Vector analysis Finance -- Management -- South Africa Economic policy -- South Africa Banks and banking -- South Africa Investments -- South Africa
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: vital:1048 , http://hdl.handle.net/10962/d1006197
- Description: Financial liberalization in South Africa was a process that took the form of various legal reforms very a long period of time. This study uses quarterly financial data from 1969 quarter one to 2009 quarter four to analyse this process. The data used was pertinent to the financial liberalization theorem by McKinnon (1973) and Shaw (1973). The examination of the relationships between the various macro economic variables has important implications for effective policy formulation. The empirical analysis is carried out in four phases: the preliminary analysis, the principal component analysis (PCA), the cointegration analysis and pair wise Granger causality tests. The preliminary analysis examines trends over the sample period and reports the on the correlation between the selected variables. The PCA analysis was used to create indexes for financial liberalization, taking into account the phase wise nature of legal reforms. The generated index was representative of the process of financial liberalization from 1969 to 2009. A financial development index was also created using the various traditional measures of financial development and through PCA which investigated interrelationships among the variables according to their common sources of movement. Cointegration analysis is carried out using the Johansen cointegration procedure which investigates whether there is long-run comovement between South African economic growth and the selected macroeconomic variables. Where cointegration is found, Vector Error-Correction Models (VECMs) are estimated in order to examine the short-run adjustments. For robustness, many control variables were added into the model. The results showed that there are positive long run relationships between economic growth and financial liberalization, financial development and a negative relationship with interest rates. The Granger results suggested that the MS hypothesis does not manifest accurately in the South African data. The implications of the results were that financial liberalization has had positive effects on economic growth and thus any impediments to full financial liberalization must be removed albeit with considerations towards employment and local productivity. Financial development also possessed positive long run relationships with economic growth, although results differed based on the financial development proxy used. Thus, financial development must be improved primarily through liberalizing the banking sector and spurring savings.
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- Date Issued: 2012
Taxing recurrent services rendered by a foreign company to an associated enterprise in South Africa
- Authors: Costa, David Patrick Anthony
- Date: 2013
- Subjects: Vienna Convention on the Law of Treaties (1969) Tax administration and procedure -- South Africa Double taxation -- South Africa Income tax -- Law and legislation -- South Africa
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: vital:906 , http://hdl.handle.net/10962/d1008269
- Description: The objective of the study was to investigate the right of the South African Government to tax the income earned by a foreign company when rendering services in South Africa to a South African associated enterprise on a recurrent basis, together with the right to tax the amounts paid to the employees of the permanent establishment for services rendered in South Africa. At the same time the research investigated whether the services rendered by a foreign company to an associated enterprise in South Africa on a recurrent basis would constitute a permanent establishment, as this is essential before South Africa may tax either the foreign company or the employees of the permanent establishment (where such employees are not resident in South Africa).The research was conducted by means of a critical analysis of documentary data and data from a limited number of interviews with academics and the authors of textbooks and articles. In order to limit the scope of the research, a number of assumptions were made. Conflicting viewpoints underlying certain of these assumptions were discussed. Some of the important conclusions reached are that the provisions of the Vienna Convention on the Law of Treaties should be taken into account when interpreting South African legislation (including Double Tax Agreements), and that the Organisation for Economic Cooperation and Development (OECD) Commentary may be relied upon when interpreting OECD based Double Tax Agreements in South Africa. No conclusion was reached on whether to apply an ambulatory or a static basis of interpreting the OECD Commentary, however. The final conclusion of the research is that the services rendered in South Africa on a recurrent basis would be geographically and commercially coherent and consequently meet the "location test'. It is clear that as the services are rendered regularly and recurrently, they would be regarded as having the necessary permanence and would meet the 'duration test'. The place of business would therefore be regarded as being fixed (having the necessary degree of permanence). As the services would be rendered at the place of business of the South African entity, they would be regarded as being rendered 'through' the place of business and the foreign entity would be regarded as having a permanent establishment in South Africa (as defined in Article 5(1) of the OECD Model Tax Convention}. The South African Government would therefore be entitled to tax the income attributable to the permanent establishment and the income earned by the non resident employees, who rendered services in South Africa for the permanent establishment. Once the entitlement to tax exists, South African legislative rules determine how South Africa proceeds to tax the income.
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- Date Issued: 2013
The tax benefits available to investors in immovable property in South Africa
- Authors: Baines, Daniel
- Date: 2016
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: http://hdl.handle.net/10962/4026 , vital:20589
- Description: The object of this thesis is to provide guidelines relating to the tax benefits that are available to investors in immovable property in South Africa. This was done by analysing the various sections of the Income Tax Act, as well as case law and South African Revenue Service guidelines that interpret these sections, which provide for expenditure which may be deducted by taxpayers from their income when conducting the trade of letting immovable property in order to reduce their overall tax liability. The thesis also includes a chapter dealing with the four different types of vehicles that taxpayers may use when investing in property. It was found that there are significant tax benefits available to investors in immovable property through the general deductions provided in terms of section 11(a) of the Act, as well as the specific deductions that the legislature has promulgated for investors in immovable property. It was also found that each of the four vehicles has its own advantages and that a taxpayer’s personal circumstances will dictate which of the vehicles will best suit his or her needs.
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- Date Issued: 2016
Willingness to pay for marine-based tourism within the Ponto do Ouro Partial Marine Reserve, Mozambique
- Authors: Daly, Clare Amelie Keating
- Date: 2014
- Subjects: Ponto do Ouro Partial Marine Reserve , Marine ecotourism -- Mozambique , Marine ecotourism -- Economic aspects -- Mozambique , Marine ecotourism -- Mozambique -- Marketing , Ecotourism -- Economic aspects -- Mozambique , Coastal zone management -- Mozambique , Marine resources conservation -- Mozambique
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: vital:1102 , http://hdl.handle.net/10962/d1013304
- Description: Marine and coastal ecosystems face widespread degradation largely because market failure hides the economic value of the goods and services provided by them. Marine protected areas (MPAs) can serve as a structure that ensures the continuing function of marine and coastal ecosystem goods and services. Yet, to be effective and sustainable, MPAs must be able to prove their economic worth and generate revenue. User-fees are a common system used to partially finance multi-use MPAs. This study applies contingent valuation as a method of economic valuation within an MPA in southern Mozambique. The objectives of this study are to determine the willingness to pay of combined user groups and of individual user groups for use of the Ponta do Ouro Partial Marine Reserve and to investigate the potential for the reserve to increase revenues for conservation through the implementation of a user-fee for marine based activities. The payment card contingent valuation method was employed to determine willingness to pay of dolphin swim tourists, scuba divers and fishermen. Data was collected by face-to-face interviews of 120 respondents within two popular tourist locations in the PPMR. Results show that visitors within the PPMR are mainly South Africans, loyal to the area. Probit and OLS regressions were used to determine the effects of various independent variables on willingness to pay. Results from the Probit model indicate that African residency, activity and environmental awareness were significant factors that influenced visitors being WTP more than R20 per person per day as a user fee within the PPMR. The OLS model examined independent variables that influenced visitors being willing to pay as well as the impact of the variables on the amount visitors were willing to pay. The OLS model found income, African residency and environmental awareness to be significant factors influencing visitors being willing to pay. The mean WTP was R43.75 per person per day. Using data supplied by the PPMR, conservative estimated annual revenues based on the implementation of this fee amount would range between R1.46m – R 3.3m.
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- Date Issued: 2014