Many companies engage in behaviour that is intended to reduce, mitigate or avoid the amount of taxation that would otherwise be due. This behaviour may result in changes to the tax code of a country and in comments being made and actions undertaken by governments, academics and other interested parties. This thesis argues that there exists a lack of clarity, coherence and consistency when considering and seeking to understand the relationship between tax codes, companies and society. This thesis argues that it is necessary to critically examine the nature of the tax related behaviour and also to identify and describe the rights, duties and obligations that are associated with the type of organisation which can be identified as a UK incorporated limited company. It is further argued that such a critical examination will require consideration of the nature of a company and the role played by directors of a company. The thesis provides an explanatory framework for tax related behaviour and uses that framework to identify and describe various types of tax related behaviour. The thesis also provides a critical discussion of the nature of the corporation and argues for the existence of a core set of rights, duties and obligations which help to illuminate the relationship between a UK incorporated limited company, the tax code and society.

This study aimed to assess the determinants and deterrents of profit shifting, which can occur as a result of corporate income tax competition, with a view to aid in collecting sufficient tax revenue to meet public spending requirements. The study theoretically and empirically analysed the effectiveness of the introduction of the South African transfer pricing regulations on deterring the occurrence of profit shifting in South Africa using annual financial information of South African parented multinational enterprises for the period 2010 – 2017. The study established that the implementation of transfer pricing regulations resulted in a reduction in profit shifting that became increasingly more prominent as the rules became stricter. Based on the findings of the study, it is recommended that the South Africa government should allocate sufficient resources to ensure that the transfer pricing regulations are being adhered with an aim to reduce profit shifting from South Africa. / Economics / M. Com. (Economics)