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Cloud computing activities : South African normal tax source determination

Nel, Rudie ; Steenkamp, Shene (2016)

CITATION: Nel, R. & Steenkamp, S. 2016. Cloud computing activities : South African normal tax source determination. Journal of Economic and Financial Sciences, 9(2):529-544.

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The 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, service and royalty income, and/or income from know-how) by performing a doctrinal study based on South African and international literature. This study identified and formulated the challenges in applying traditional source tests in the context of cloud-based transactions. These challenges stem from the potential absence of physical presence of the provider in the country of consumption, in contrast to traditional source tests where physical presence indicate a tax presence; as well as the location-independent nature of cloud-based transactions from the perspective of both the provider and the consumer. The findings of the study suggest that the source determination for cloud-based transactions could be based on the source of the payment or residency of the payer, rather than the physical location.

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