Includes abstract.Includes bibliographical references.The aim of this dissertation is to establish the relevance of the international interpretation of beneficial owner to SA’s interpretation of the concept. The phrase “beneficial owner” was introduced into the South African Income Tax Act in April 2012 following an intention to align South African tax as regards dividends with international norms. The concept is applied in a domestic context by various countries and in numerous bilateral tax treaties and has been a subject of debate across numerous foreign courts
The concept of “beneficial ownership” is frequently used in international tax treaties. The concept ...
Celem niniejszej pracy jest analiza roli klauzuli rzeczywistego beneficjenta w międzynarodowym prawi...
The term ‘beneficial owner’ has been applied by Ukrainian courts and tax authorities in the area of ...
The use of conduit company treaty shopping structures is often regarded as an impermissible erosion ...
M.Com. (South African and International Taxation)The term “beneficial ownership” was first included ...
In the years since the Organisation for Economic Cooperation and Development (OECD) adopted its firs...
Beneficial owner is one of the most important concepts used in tax treaties. It limits the benefit o...
Free movement of goods, capital, workers and services have stimulated economic and social interactio...
M.Com. (SA and International Tax)The term “beneficial owner” is found in 64 of the 71 double tax agr...
Thesis (MComm) -- Stellenbosch University, 2011.ENGLISH ABSTRACT: The study’s focus is to provide an...
Thesis (M.Com.)-University of KwaZulu-Natal, Westville, 2004.No abstract available
This dissertation seeks to explore the issue of beneficial ownership requirement in international ta...
This authoritative book provides a structural, global view of evolving judicial and doctrinal trends...
The term ‘beneficial owner’ was first internationally introduced by the OECD in the Model Convention...
Includes abstractIncludes bibliographical references.This thesis adds to the body of literature expl...
The concept of “beneficial ownership” is frequently used in international tax treaties. The concept ...
Celem niniejszej pracy jest analiza roli klauzuli rzeczywistego beneficjenta w międzynarodowym prawi...
The term ‘beneficial owner’ has been applied by Ukrainian courts and tax authorities in the area of ...
The use of conduit company treaty shopping structures is often regarded as an impermissible erosion ...
M.Com. (South African and International Taxation)The term “beneficial ownership” was first included ...
In the years since the Organisation for Economic Cooperation and Development (OECD) adopted its firs...
Beneficial owner is one of the most important concepts used in tax treaties. It limits the benefit o...
Free movement of goods, capital, workers and services have stimulated economic and social interactio...
M.Com. (SA and International Tax)The term “beneficial owner” is found in 64 of the 71 double tax agr...
Thesis (MComm) -- Stellenbosch University, 2011.ENGLISH ABSTRACT: The study’s focus is to provide an...
Thesis (M.Com.)-University of KwaZulu-Natal, Westville, 2004.No abstract available
This dissertation seeks to explore the issue of beneficial ownership requirement in international ta...
This authoritative book provides a structural, global view of evolving judicial and doctrinal trends...
The term ‘beneficial owner’ was first internationally introduced by the OECD in the Model Convention...
Includes abstractIncludes bibliographical references.This thesis adds to the body of literature expl...
The concept of “beneficial ownership” is frequently used in international tax treaties. The concept ...
Celem niniejszej pracy jest analiza roli klauzuli rzeczywistego beneficjenta w międzynarodowym prawi...
The term ‘beneficial owner’ has been applied by Ukrainian courts and tax authorities in the area of ...