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The incorporation of double taxation agreements into South African domestic law
There are different opinions as to the process whereby double taxation agreements (DTAs) are incorporated into South African law. This contribution aims to discuss some of the existing opinions and to offer a further ...
A comparative perspective on the "joint-action rule" in the context of business trusts
(Juta Law Publishing, 2014-01)
The "joint-action rule" in South African trust law entails that all trustees must act jointly in order to bind the trust. Non-compliance with the rule will most often lead to the invalidity of a contract between the trustees ...
Deductibility of royalties: a recent case that ruffled feathers [Discussion of the judgment of Waglay J in case number 11454 in the tax court]
(Juta Law Publishing, 2006-01)
INTRODUCTION: The Tax Court, sitting in Cape Town, recently had occasion to consider the deductibility of royalty payments.1 In general it may be said that royalties are payments for the use of another’s intellectual ...
The interpretation of double taxation agreements : a comparative evaluation of recent South African case law
(Juta Law, 2016-10)
Vogel and Rust describe the act of interpretation as unfolding a text, to bring it to be understood. The South African courts have recently had a number of opportunities to interpret double taxation agreements entered into ...
Die aftrekbaarheid van rente en huurgeld vir inkomstebelastingdoeleindes
(Juta Law, 2007-01)
In die onderhawige saak het BP Suid-Afrika (Edms) Beperk ("BPSA") op 'n kwartaallikse grondslag dividende aan sy houermaatskappy, BP Plc, verklaar. Sodanige verklarings is deur die houermaatskappy vereis. BPSA het in die ...
A South African perspective on some critical issues regarding the OECD model tax convention on income and on capital, with special emphasis on its application to trusts
(Stellenbosch : Stellenbosch University, 2014-12)
ENGLISH ABSTRACT: Trusts are used for a variety of purposes, both in South Africa and abroad. Like so many other entities, trusts often do not function only in one jurisdiction and may therefore be exposed to international ...