Download or read book Tax Convention with South Africa written by South Africa and published by . This book was released on 1997 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Tax Convention with South Africa written by South Africa and published by . This book was released on 1997 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Explanation of Proposed Income Tax Treaty Between the United States and the Republic of South Africa written by and published by . This book was released on 1997 with total page 62 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Convention with the Union of South Africa with Respect to Taxes on the Estates of Deceased Persons written by South Africa and published by . This book was released on 1947 with total page 14 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Tax Convention with South Africa written by South Africa and published by . This book was released on 1997 with total page 68 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Conventions with South Africa New Zealand Norway Ireland Greece and Canada on Double Taxation written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 1951 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book South Africa Treaties and Tax Information Exchange Agreements written by U. S. Department U.S. Department of the Treasury and published by . This book was released on 2014-11-07 with total page 94 pages. Available in PDF, EPUB and Kindle. Book excerpt: This document is a technical explanation of the Convention between the United States and South Africa which was signed on February 17, 1997 (the "Convention"). References in this Explanation to the "U.S. Model" are to the United States Model Income Tax Convention, published on September 30, 1996. References to the "OECD Model" are to the Model Tax Convention on Income and on Capital, published by the OECD in 1992, as subsequently amended. References to the "U.N. Model" are to the United Nations Model Double Taxation Convention between Developed and Developing Countries, published in 1980.The Technical Explanation is an official guide to the Convention. It reflects the policies behind particular Convention provisions, as well as understandings reached with respect to the application and interpretation of the Convention.

Download or read book Tax Convention with South Africa United States Treaty written by The Law Library and published by Independently Published. This book was released on 2019-01-29 with total page 88 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Law Library presents the complete text of the Tax Convention with South Africa (United States Treaty) Updated as of 01/28/19 This ebook contains: - The complete text of the Tax Convention with South Africa (United States Treaty) - A dynamic table of content linking to each section - A table of contents in introduction presenting a general overview of the structure

Download or read book Tax Convention with South Africa Report 105 11 written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 1997 with total page 55 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Department of the Treasury Technical Explanation of the Convention Between the United States of America and the Republic of South Africa written by United States United States Government and published by CreateSpace. This book was released on 2015-01-02 with total page 96 pages. Available in PDF, EPUB and Kindle. Book excerpt: This document is a technical explanation of the Convention between the United States and South Africa which was signed on February 17, 1997 (the "Convention"). References in this Explanation to the "U.S. Model" are to the United States Model Income Tax Convention, published on September 30, 1996. References to the "OECD Model" are to the Model Tax Convention on Income and on Capital, published by the OECD in 1992, as subsequently amended. References to the "U.N. Model" are to the United Nations Model Double Taxation Convention between Developed and Developing Countries, published in 1980.

Download or read book Protocol with the Union of South Africa Relating to Taxes on Income written by United States and published by . This book was released on 1950 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by Kluwer Law International B.V.. This book was released on 2021-09-28 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.

Download or read book Interim Report of the Commission of Inquiry Into Certain Aspects of the Tax Structure of South Africa Fifth interim report written by Commission of Inquiry into Certain Aspects of the Tax Structure of the Republic of South Africa and published by . This book was released on 1994 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Interpretation of South African Double Taxation Agreements Under International Law written by Benhardt Laurentius Johannes and published by . This book was released on 2014 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This dissertation interrogates which principles should govern the interpretation of South African Double Tax Agreements (DTAs'). This field of study is complex because any DTAs have a dual nature. In the first place, it is an international agreement where two states are parties (a bilateral agreement): second, it also becomes part of domestic law. DTAs are governed by principles of customary international law some of which have been codified in the Vienna Convention on the Law of Treaties (VCLT). Though South Africa is not a party to the VCLT, nevertheless, there is judicial support in South Africa for the notion that VCLT reflects general principles of international law [Harksen v President of the Republic of South Africa 1998 (2) SA 1011 (C)]. DTAs are incorporated into South African domestic law by way of statutory enactment in accordance with the dualist approach to international law. The first purpose of the dissertation is to systematise and analyse the structure of an OECD Model Tax Convention (OEC D MTC) and the international methods (principles) of interpretation of DTAs in order to gain a better understanding of how this international methods functions. A number of issues relating to the interpretation of these methods are analysed. Since DTAs are applied by tax authorities, courts and taxpayers in a domestic law context, i.e. within the framework of the legal system of a particular state, the analysis focuses on the application in South Africa of the methods of the interpretation of South African DTAs. The second objective of the dissertation refers to international tax law principles (treaties and customary international law) derived from South Africa public international law and to evaluate a few selected issues related to South African DTAs and their relevance to South Africa domestic tax laws: the interpretation of DTAs and the implications of a DTA overriding or in conflict with South Africa domestic tax laws. It will also interrogate the legal status of a DTA under South African tax law and whether the anti-discrimination article in South Africa DTAs have the force of law in South Africa?

Download or read book International Tax written by Lynette Olivier and published by . This book was released on 2008 with total page 638 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book gives an overview of international tax aspects from a South African perspective. These topics include: taxation of controlled foreign companies, tax treatment of foreign dividends, exchange controls, tax havens, intermediate holding companies, and double-taxation agreements. It also includes the latest international tax amendments to the South African Income Tax Act up to August 2007, tax treaties signed by South Africa, overseas court cases, examples of tax treaty application, and an expanded glossary.

Download or read book International Tax written by Michael Honiball and published by Siber Ink. This book was released on 2011-03-15 with total page 908 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is not merely a new edition, but a complete and significantly expanded rewrite. It comprises over 900 pages of expert and in-depth exposition of this complex subject that has become so important in the modern global economy. Already established over four previous editions as the pre-eminent work on the subject it is a 'must-own book' for all students and practitioners of tax, whether from a legal, business or accounting perspective. Professor Lynette Olivier and Michael Honiball are without peer in their understanding and clarity in this highly specialised field. Five new chapters have been added on: Taxation of individuals; Taxation of Companies and Dividends; Taxation of Partnerships; Cross-border VAT; and Interpretation of Statutes.

Download or read book Convention Between the Republic of South Africa and the Republic of Tunisia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income written by South African Revenue Service and published by . This book was released on 1999 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: