Bibliography: pages [115]-120. / This thesis establishes a group income tax system for South Africa so that equity may be achieved between the burden of company income tax borne by shareholders who invest in companies that are structured through subsidiaries and shareholders that invest in companies that are structured through divisions. For example, intercompany profits and losses of a revenue nature are subject to income tax whereas interdivisional profits or losses of a revenue nature are not subject to income tax. Also, tax losses incurred by a company are not deductible from taxable income of other companies within the same group whereas in the case of a company that is structured through divisions losses incurred by a division are deductible from income of other divisions of the same company. The study is classified as 'microcomparison' whereby legal problems that exist in one country are studied on a comparative legal basis. Accordingly, the objective of the thesis is achieved by undertaking a comparative study of group income tax law in the United Kingdom and United States of America for equitable group income tax treatment of problems that exist within the current South African company income tax system. First, the definition of 'a group' is established, after which a group income tax treatment of group transactions and tax losses is established to eliminate the inequities that are inherent in the South African income tax system. Throughout the study it is demonstrated that these inequities exist in spite of the current income tax avoidance provisions (for example s103 and the connected persons rules). The conclusions made in the study indicate that the inequity that exists in the South African company income tax system should be eliminated.

No description available.

Thesis (M.B.A.)--Boston University

"The Income Tax Acts themselves impose a territorial limit; either that from which the taxable income is derived must be situate in the United Kingdom or the person whose income is to be taxed must be resident there", per Lord Herschell in Colquhoun v Brooks (1889) 2 TC 490 at 498 These remarks by Lord Herschell even though directed at the United Kingdom tax system in 1889 seem to capture the situation in the new tax law in Lesotho. A recurring question for any tax system to date is is taxation by either residence and/or source appropriate? This question inspired my research into the examination of the new Lesotho Income Tax Order No 9 of 1993.

No description available.

From Introduction: This work considers the period from Union, 31 May 1910 until promulgation of the Income Tax Act No. 40 of 1925.(1) It will describe the means, both financial and otherwise, by which the fledgling Government of the Union of South Africa contrived to balance its budget, and will consider the various sources of revenue available up to 1914, when the Government of Gen. Louis Botha first decided that a tax on income was necessary in order to maintain the solvency of the new State. Similarly the political pressures which shaped the nature of the Income Tax Acts up to 1925 will be discussed, and the political principles (or expediencies, depending on the degree of cynicism of the reader) which led the parties in power from time to time to make the decisions they did regarding the provisions of the various Acts. The effect of external political situations such as the Great War of 1914 - 1918 will be examined, as will the consequences of the rebellion of 1914 and the strikes of 1913 and 1922. The legislation predictably spawned a considerable body of litigation as taxpayers hastened to find and exploit loopholes in it; the resultant Income Tax Cases, in the Income Tax Special Court, Supreme Court and Appeal Court, formed the embryo of a body of judicial precedent which today encompasses some two thousand case reports. A few of the cases decided in the period up to 1925 are still quoted today; for example, CIR v Lunnon 1924 AD 1 SATC 7. The relevant cases from the period will enjoy consideration, with descriptions of how their verdicts affected either subsequent income tax principles or later legislation. Also considered will be the inception during this period of the way in which income tax legislation largely develops: the legislature promulgates an Act, the taxpayers discover legitimate ways to reduce their tax burden and the Minister of Finance consequently causes the Act to be changed in order to protect the tax base. Thereupon the resolute taxpayers seek loopholes anew. The effect of economic conditions on income tax legislation will engage attention; several such conditions cast their shadows into the House of Assembly during that 15 year period, notably the post-war recession and the drought of 1919. The selection of this period is apposite for several reasons: it covers the period during which income tax legislation came into being; - it includes several notable political occurrences. thus making possible a consideration of their effect on income tax legislation; it includes a natural cataclysm. namely a major drought. which also had an effect on subsequent Income Tax Acts; - a sufficient number of income tax cases was heard during the period to afford a fair indication both of how the body of case law would develop and how it would perpetually interplay with the legislation; it clearly illustrates the differences between the two great political parties of the time, differences largely caused by the vested interests of each; the dominant South African Party, with its need to retain the support of the commercial and particularly the mining sectors, and the smaller but even then growing National Party with its face set firmly towards the rural constituencies and the embattled farmers; - the period culminates in the Income Tax Act of 1925, a significant change from its predecessors, and the second Income Tax Act of the Pact Government. The imposition of taxes by the respective provinces does not form part of this work, as the scope of the discussion is limited to the various Income Tax Acts, and their development has been overseen by the central government.

The purpose of this study is to analyze the system of personal income taxation in Nigeria, especially with respect to its administration, equity, and effects on efficient resource usage. There have, in the past, been numerous complaints that the personal income tax in Nigeria does not yield enough revenue for the state governments, primarily because of widespread avoidance and evasion of the tax, especially by persons who do not derive income from wages and salaries. This study examines this problem in light of questions as to how the tax evolved, how important it is to state governments, how efficient and equitable it is, what administrative problems it faces, and what reforms can be implemented to best solve existing problems.

M.Com. / Please refer to full text to view abstract

Advertising plays a distinct role in economies around the world and, in this regard, diverse countries have been investigated in this study including the BRICS countries. It focused on the classification of advertising cost for tax purposes. Research questions posed by this study are answered through the development of a classification process that may assist with the classification of advertising cost for the purpose of taxation. It has been established that guidelines for the classification of advertising cost as capital or revenue of nature are needed to correctly classify advertising cost for tax purposes. Furthermore, the determination of when advertising cost will be regarded as capital of nature is required. The study used a mixed method research approach, involving a literature review of case law and income tax acts as well as an analysis of annual financial statements. Findings from this research indicate a growing trend in revenue generated from advertising in South Africa; proving the importance of the advertising market in the economy. Guidelines for the classification of advertising cost for tax purposes were established by using principles from national and international case law. / MCom (Accountancy)--North-West University, Vaal Triangle Campus, 2015

Advertising plays a distinct role in economies around the world and, in this regard, diverse countries have been investigated in this study including the BRICS countries. It focused on the classification of advertising cost for tax purposes. Research questions posed by this study are answered through the development of a classification process that may assist with the classification of advertising cost for the purpose of taxation. It has been established that guidelines for the classification of advertising cost as capital or revenue of nature are needed to correctly classify advertising cost for tax purposes. Furthermore, the determination of when advertising cost will be regarded as capital of nature is required. The study used a mixed method research approach, involving a literature review of case law and income tax acts as well as an analysis of annual financial statements. Findings from this research indicate a growing trend in revenue generated from advertising in South Africa; proving the importance of the advertising market in the economy. Guidelines for the classification of advertising cost for tax purposes were established by using principles from national and international case law. / MCom (Accountancy)--North-West University, Vaal Triangle Campus, 2015