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Double taxation could arise in a situation where resident- resident conflicts occur. Resident–resident conflicts occur in the situation where both countries regard such a person as a “resident” for tax purposes under their domestic legislation. For that reason, all income that is earned by that person, irrespective of the jurisdiction it is earned in, will be subject to tax in both countries. In order to resolve these conflicts, the Organisation for Economic Cooperation and Development’s (“OECD’s”) Model Tax Convention contains a tie breaker clause which states that a non-individual shall be deemed to be a resident only of the State in which the ‘place of effective management’ is situated. It was found that although there were conflicting views, the expression ‘place of effective management’ was mainly determined with reference to the place where real management actually makes decisions on key business affairs of the company. Based on the following reasons it was concluded that using ‘place of effective management’ as a tie breaker rule was ineffective. • With improved communication technology and increased mobility of top level management, it makes it very difficult to pinpoint a single location where the ‘place of effective management’ is positioned; • Changes to the generic managerial structures seen in the past, makes it increasingly complex to determine where the ‘place of effective management’ is situated; and • There is no universal interpretation of the term ‘place of effective management’ within the international arena. Against the backdrop that each option for determining the ‘place of effective management, analysed in Chapter 4 had its own flaws, it is almost impossible to determine a company’s residency based on a single test. It was therefore, recommended that the tie breaker rule consist of a hierarchy of the following tests. 1. Deemed to be resident of the country in which place of effective management is situated, as defined by SARS’ interpretation. 2. Deemed to be a resident of the country in which its economic nexus is the strongest. 3. Conflict to be resolved by mutual agreement between the two Contracting States. / Thesis (M.Com. (Tax))--North-West University, Potchefstroom Campus, 2011.

Double taxation could arise in a situation where resident- resident conflicts occur. Resident–resident conflicts occur in the situation where both countries regard such a person as a “resident” for tax purposes under their domestic legislation. For that reason, all income that is earned by that person, irrespective of the jurisdiction it is earned in, will be subject to tax in both countries. In order to resolve these conflicts, the Organisation for Economic Cooperation and Development’s (“OECD’s”) Model Tax Convention contains a tie breaker clause which states that a non-individual shall be deemed to be a resident only of the State in which the ‘place of effective management’ is situated. It was found that although there were conflicting views, the expression ‘place of effective management’ was mainly determined with reference to the place where real management actually makes decisions on key business affairs of the company. Based on the following reasons it was concluded that using ‘place of effective management’ as a tie breaker rule was ineffective. • With improved communication technology and increased mobility of top level management, it makes it very difficult to pinpoint a single location where the ‘place of effective management’ is positioned; • Changes to the generic managerial structures seen in the past, makes it increasingly complex to determine where the ‘place of effective management’ is situated; and • There is no universal interpretation of the term ‘place of effective management’ within the international arena. Against the backdrop that each option for determining the ‘place of effective management, analysed in Chapter 4 had its own flaws, it is almost impossible to determine a company’s residency based on a single test. It was therefore, recommended that the tie breaker rule consist of a hierarchy of the following tests. 1. Deemed to be resident of the country in which place of effective management is situated, as defined by SARS’ interpretation. 2. Deemed to be a resident of the country in which its economic nexus is the strongest. 3. Conflict to be resolved by mutual agreement between the two Contracting States. / Thesis (M.Com. (Tax))--North-West University, Potchefstroom Campus, 2011.

Approved for public release; distribution in unlimited. / This thesis examines the evolution of NATO as an institution in the International System by reference to Articles 4, 5 and 6 of the Washington Treaty of 1949. Initially, the thesis considers NATO from an international relations perspective. It then proceeds to examine the institutional evolutionary process of the Alliance since its inception and implementation in 1949. Furthermore, it explores the significance and the meaning of the aforementioned Articles. This thesis utilizes the case study method and refers to four distinct events that have shaped allied policies and strategies: the Suez Crisis of 1956, the establishment of the politico-military consultation process, the Yom Kippur War (1973), and the end of the Cold War (1989-1991). It also examines the allied policies after the events of September 11, 2001. Moreover, it identifies a general pattern of events pertinent to crisis creation inside NATO when the organization is facing a defense issue outside the Euro-Atlantic area. Finally, the thesis concludes that NATO is more than an ordinary military Alliance, as advocated by its longevity, agility and adaptability, which allows the Alliance to maintain a central position in the International System as a robust politico-military organization. / Lieutenant Commander, Hellenic Navy

This research aims to investigate the understanding, attitudes and application of Article 4 of the Belhar Confession by Melodi ya Tshwane (MyT). The aim specifically outlines the current mission praxis of MyT and its missionary activities, the church’s missionary calling in line with Article 4 of Belhar , evaluate the extent to which Article 4 of Belhar is applied, and to propose missionary praxis for MyT . The research findings include: participants have a narrow understanding of missions; conducting outreach activities in the form of charity. Some gaps identified include: lack of understanding of God as the missionary God, and a narrow interpretation of justice. Guiding principles on being missional include: missions should be Christ-centred, relational, collaborative, transformational, and lived out in word and deed. Proposed mission praxis consider the following approaches: the church as an institution, as a living organism and the church’s corporate service, and missional consciousness. / Christian Spirituality, Church History and Missiology / M. Th. (Missiology)