La presente investigación tiene como propósito demostrar el impacto que tiene el artículo 32-A de la Ley del Impuesto a la Renta, sobre el test de beneficio, en los servicios intragrupo en las empresas bancarias. La investigación se fundamenta con base a las normas recomendadas por la OCDE para que las empresas puedan aplicar de manera óptima el Test de beneficio en los servicios intragrupo. El Capítulo I expone el Marco Teórico en el que se encuentran las principales definiciones como bases legales, además de los ámbitos de aplicación e investigaciones realizadas en otros países con el propósito de brindar más información para un mejor entendimiento del tema principal. El Capítulo II presenta el Plan de Investigación, en el cual se definen el problema, objetivo e hipótesis generales como específicas. El Capítulo III exhibe la Metodología del trabajo, siendo la investigación será de carácter mixto (cualitativa y cuantitativa) con el manejo de la muestra. El Capítulo IV se enseña el desarrollo y la aplicación mediante los instrumentos lo cual serán planteados en el capítulo anterior. Por último, en el Capítulo V se observan los Análisis de resultados, desarrollo de la propuesta, conclusiones y recomendaciones del tema de investigación. / The purpose of this research is to demonstrate the impact of article 32-A of the Income Tax Law, on the benefit test, on intra-group services in banking companies. The research is based on the standards recommended by the OECD so that companies can optimally apply the Profit Test in intra-group services. Chapter I exposes the Theoretical Framework in which the main definitions are found as legal bases, in addition to the fields of application and research carried out in other countries with the purpose of providing more information for a better understanding of the main topic. Chapter II presents the Research Plan, in which the problem, objective and general and specific hypotheses are defined. Chapter III exhibits the Methodology of the work, being the investigation will be of a mixed nature (qualitative and quantitative) with the handling of the sample. Chapter IV teaches the development and application through the instruments which will be raised in the previous chapter. Finally, in Chapter V the Analysis of results, development of the proposal, conclusions and recommendations of the research topic are observed. / Tesis

Trusts are subject to multiple fOl1lls of legislative regulation dealing with taxation and governance. Trusts were widely used by planners as taxavoidance shelters. Tax legislation was amended to subject trusts, other than special trusts as defined, to the highest income tax rate of forty percent, in tel1llS of section 5(2) of the Income Tax Act, 58 of 1962. The inter vivos trust is also subject to a wide range of anti-avoidance measures, including those contained in sub-sections (3) to (8) of section 7 of the Income Tax Act and Part X of the Eighth Schedule to the Act, as well as the general anti -avoidance measures in section 103. These measures impact negatively on the use of trusts for estate-planning purposes. The research objective was to evaluate the use of testamentary and inter vivos trusts for estate-planning purposes and to develop a holistic estate-planniD.g model incorporating these planning instruments. Both the testamentary trust and the inter vivos trust were evaluated against broad principles of effective estate planning and the taxes and duties applicable to them. The research also reviewed the writings of financial planners on various techniques and models used for estate planning, as wells as case studies documented in the literature. The research developed and evaluated holistic estate-planning models incorporating testamentary trusts and inter vivos trusts, respectively. By neutralizing the effects of various taxes and duties, it was demonstrated that it is possible to develop an estate plan that satisfies most of the requirements of effective estate planning.

The thesis deals with the topic of employee benefits in the Czech Republic. At first, the thesis sets employee benefits to specific area of the company, which is an in-house social policy of the company. Following part deals with the legislative framework, which regulates the providing of these benefits in 2015. The thesis includes a chapter describing the employee benefits, their structure and their various distribution systems. Analysis of the trends in the provision of employee benefits creates another part of the thesis. Three types of employee benefits are analyzed in detail: meal allowances, educational allowances and contributions to employees' pension savings. In the conclusion of thesis is explored the whole system of employee benefits used in the company Siemens Ltd., where are analyzed its individual benefits and includes evaluation of a questionnaire.

In support of a short dissertation entitled - "A critical review of the source and residence principles of taxation of income : A place for both principles in the South African tax system?" Qbjeetives To review and critically examine the application of the source and reside.nce principles regarding the taxption of income in South Africa, and to reveal the extent of the existence and application of a hybrid tax system in respect of the source and residence principles. To examine the legal principles and policy considerations arising from the existence of a hybrid tax system, inter alia, in the context of the Fifth Interim Report of the Katz Commission and consequent legislative developments. with a view to recommending. where appropriate, tax reform. Methodology iDd AQProach A review of relevant authority,liter@ture, principles and legislation. Conclusion To draw conclusions and recommendations regarding the merits of adopting a hybrid system in South Africa and, where appropriate, recommend legislative reforms particularly with regard to business income. / Mercantile Law / LL.M. (Mercantile Law)

This study presents an overview of the medical expenditure allowed to taxpayers in the South African Income Tax Act, 58 of 1962 (hereafter the “Income Tax Act”). The study traces the changes made to the allowed expenditure over time. Changes made to the Income Tax Act, illustrating the effect of qualifying medical expenses on the income of persons with disabilities in terms of the Income Tax Act, are described. Certain provisions of the Income Tax Act, as well as other legislation dealing with persons with disabilities, were analysed. Furthermore, the research shows the effect of moderate to severe limitations on a person’s ability to claim qualifying medical expenses. In particular, the change over from the medical tax deduction system (section 18 of the Income Tax Act) to the medical tax rebate system (sections 6A and 6B of the Income Tax Act) to redress the inequality between high income and low income earners, was analysed. Case studies were used to illustrate that the medical tax deduction system (section 18 of the Income Tax Act) favoured high income earners over low income earners. Finally, the change over from the medical tax deductions (section 18 of the Income Tax Act) system to the current system of medical tax rebates (sections 6A and 6B of the Income Tax Act) was analysed. Except for a very small group of taxpayers, the medical tax rebate system (sections 6A and 6B of the Income Tax Act) was found to be financially more favourable to all taxpayers. / Taxation / M. Compt. (Taxation)

In support of a short dissertation entitled - "A critical review of the source and residence principles of taxation of income : A place for both principles in the South African tax system?" Qbjeetives To review and critically examine the application of the source and reside.nce principles regarding the taxption of income in South Africa, and to reveal the extent of the existence and application of a hybrid tax system in respect of the source and residence principles. To examine the legal principles and policy considerations arising from the existence of a hybrid tax system, inter alia, in the context of the Fifth Interim Report of the Katz Commission and consequent legislative developments. with a view to recommending. where appropriate, tax reform. Methodology iDd AQProach A review of relevant authority,liter@ture, principles and legislation. Conclusion To draw conclusions and recommendations regarding the merits of adopting a hybrid system in South Africa and, where appropriate, recommend legislative reforms particularly with regard to business income. / Mercantile Law / LL.M. (Mercantile Law)

This study discusses South Africa’s tax incentives for small businesses and identifies shortcomings and areas of concern within the tax incentive regimes. A comparison of small business tax incentives provided by Australia, India, and the United Kingdom is made with South Africa’s small business tax incentives to identify similarities and differences, and new lessons are learned from the approaches of other countries. As a result of the comparison with the tax dispensations available to small businesses in other countries, the study recommends additional tax incentives that could be implemented by South Africa. Only those tax incentives that are available in other countries but not in South Africa that were deemed worthwhile were recommended to be introduced in the Republic. Recommendations were also made based on the gaps identified in South Africa’s small business tax incentives. / College of Accounting Sciences / M. Phil. (Accounting Sciences)