Cloud computing activities : guidelines on the South African income tax classification
Date
2016
Authors
Journal Title
Journal ISSN
Volume Title
Publisher
AOSIS Publishing
Abstract
The classification of income from cloud computing activities, according to the substance-over-form doctrine, is fundamental to the application of the correct taxation source test. The designation of IaaS, PaaS and SaaS, the three main cloud computing service models, clearly denotes the form of cloud computing activities as that of a service. However, the nature of cloud computing inherently raises the question of whether or not cloud computing income should not rather be classified as income from leasing activities or the imparting of know-how. In fact, the findings of this study suggest the classification would not necessarily always be that of a service. The possible classification as lease income can be either income from the lease of tangible computer hardware and/or of intellectual property (royalty income). The aim of this study was to formulate guidelines to assist in the correct classification of income from cloud computing activities. This was achieved by performing doctrinal research based on the South African and international literature.
Description
CITATION: Steenkamp, S. & Nel, R. 2016. Cloud computing activities : guidelines on the South African income tax classification. Journal of Economic and Financial Sciences, 9(1):228-243.
The original publication is available at https://jefjournal.org.za
The original publication is available at https://jefjournal.org.za
Keywords
Income tax -- South Africa, Cloud computing -- Taxation -- South Africa
Citation
Steenkamp, S. & Nel, R. 2016. Cloud computing activities : guidelines on the South African income tax classification. Journal of Economic and Financial Sciences, 9(1):228-243.