Globalisation of trade and investment has led multinational enterprises to develop strategies to maximise profits by investing in countries with a favourable tax climate, resulting in loss of tax revenue to domestic economies. In South Africa, recent economic liberalisation and associated relaxation of exchange controls have created increasing exposure to global competition, risk of capital flight and potential threat to the tax base. Heeding OECD recommendations intended to counter negative tax implications for domestic economies and curb harmful tax practices, South Africa introduced controlled foreign company provisions initially in 1997, followed by comprehensive legislation in 2001. Appropriateness of South Africa’s CFC regulations as domestic anti-avoidance measures is assessed in this study for their relevance in the international fiscal arena, highlighting key divergences, shortcomings and anomalies in the South African regulations compared with OECD recommendations, and with regulatory measures in the United Kingdom (jurisdictional-entity approach) and the United States (transactional approach), these two examplars offering paradigms of the most important CFC regulatory approaches currently in force. The primary materials investigated in the study are the statutes which constitute the taxation laws, read in conjunction with auxiliary, quasi-statutory advisory and explanatory documentation issued by the respective regulatory authorities, along with test cases that established legal precedent on points of ambiguity in taxation law. A key finding in the literature review is the relative dearth of publications on current South African CFC regulations in an international comparative context. A paradigm shift is noted in United Kingdom tax policy, as it migrates towards a territorially inclined tax system in CFC regulations – more compatible with European Union (EU) requirements and propelled in large measure by EU-pressure – with a similar trend in United States tax policy, intended to rekindle expansion and growth of the United States economy through repatriation of foreign funds earned by CFCs. The study finds that it would be unrealistic to seek an absolute paradigm for reform or evolution of South African CFC regulations in either the United Kingdom or the United States, although the South African and United Kingdom CFC measures show significant affinities in their entity-based mechanisms to grant full exemption. More significant constituents of CFC regulation in one or another of the two countries do, however, prove to be generally congenial to the South African situation and offer useful pointers for ongoing reform of the South African measures. Other areas in the United Kingdom or United States CFC regulations are identified as less relevant to South African requirements, being linked to tax principles that would be excessively complicated in the South African circumstances, needlessly demanding for tax administrators and for South African shareholders, contradictory to South African tax principles, anachronistic, or not suited for the underlying global-entity approach in the South African regulations. The research provides an updated assessment of the current state of the South African CFC regulatory measures, when seen in a broader international context, and indicates areas that could be the subject of fruitful ongoing investigation. / PhD (Tax), North-West University, Potchefstroom Campus, 2014

Globalisation of trade and investment has led multinational enterprises to develop strategies to maximise profits by investing in countries with a favourable tax climate, resulting in loss of tax revenue to domestic economies. In South Africa, recent economic liberalisation and associated relaxation of exchange controls have created increasing exposure to global competition, risk of capital flight and potential threat to the tax base. Heeding OECD recommendations intended to counter negative tax implications for domestic economies and curb harmful tax practices, South Africa introduced controlled foreign company provisions initially in 1997, followed by comprehensive legislation in 2001. Appropriateness of South Africa’s CFC regulations as domestic anti-avoidance measures is assessed in this study for their relevance in the international fiscal arena, highlighting key divergences, shortcomings and anomalies in the South African regulations compared with OECD recommendations, and with regulatory measures in the United Kingdom (jurisdictional-entity approach) and the United States (transactional approach), these two examplars offering paradigms of the most important CFC regulatory approaches currently in force. The primary materials investigated in the study are the statutes which constitute the taxation laws, read in conjunction with auxiliary, quasi-statutory advisory and explanatory documentation issued by the respective regulatory authorities, along with test cases that established legal precedent on points of ambiguity in taxation law. A key finding in the literature review is the relative dearth of publications on current South African CFC regulations in an international comparative context. A paradigm shift is noted in United Kingdom tax policy, as it migrates towards a territorially inclined tax system in CFC regulations – more compatible with European Union (EU) requirements and propelled in large measure by EU-pressure – with a similar trend in United States tax policy, intended to rekindle expansion and growth of the United States economy through repatriation of foreign funds earned by CFCs. The study finds that it would be unrealistic to seek an absolute paradigm for reform or evolution of South African CFC regulations in either the United Kingdom or the United States, although the South African and United Kingdom CFC measures show significant affinities in their entity-based mechanisms to grant full exemption. More significant constituents of CFC regulation in one or another of the two countries do, however, prove to be generally congenial to the South African situation and offer useful pointers for ongoing reform of the South African measures. Other areas in the United Kingdom or United States CFC regulations are identified as less relevant to South African requirements, being linked to tax principles that would be excessively complicated in the South African circumstances, needlessly demanding for tax administrators and for South African shareholders, contradictory to South African tax principles, anachronistic, or not suited for the underlying global-entity approach in the South African regulations. The research provides an updated assessment of the current state of the South African CFC regulatory measures, when seen in a broader international context, and indicates areas that could be the subject of fruitful ongoing investigation. / PhD (Tax), North-West University, Potchefstroom Campus, 2014

"The purpose of the study is two-fold: (1) to compare the 1939-40 living conditions that prevailed in the men's college dormitory with living conditions that existed in sixteen college-supervised residences for men; (2) to compare the living conditions that existed in 1939-40 in both the men's dormitory and the college-supervised residences for men with standards set up by authorities in the field of college student housing."--1.

published_or_final_version / Housing Management / Master / Master of Housing Management

The master’s thesis focuses on determining of methodology for calculating of tax base in the service permanent establishment of Slovak tax resident in the Czech republic. Based on analysis of Czech accounting, tax regulations and OECD model agreement, data are used to determine the methodological manul and its subsequent application.

This thesis focuses on international taxation of individuals in the Czech Republic and Ireland. The thesis includes an explanation of taxation procedure of personal income from wages earned in Ireland while being tax resident of the Czech Republic. Relevant legislation and basic concepts of taxation are introduced as well.

This diploma thesis deals with the obligations for implementing the construction project in the Slovakia and its taxation. At first is defined basic terminology, concept of single market of the European Union and the harmonization process of direct and indirect taxation. In the analytical part of the thesis are relevant sources of international, union and national law analyzed. The practical part is focused on specification construction contract, accomplishment all obligations and an exemplary taxpayer's tax liability is calculated.

The diploma thesis deals with international taxation of theater artist’s incomes. The main aim is to create methodical instruction for income taxation of tax non-residents of The Czech Republic. After that the methodical instruction is used for calculation of the tax liability of model tax payers - theater artists. The diploma thesis also evaluates case-law which deals with international taxation and defines possible risks which eventuate from incorrect interpretation.

Urban green spaces such as neighbourhood parks and playgrounds hold significance because they offer services and benefits related to human health and wellbeing. Despite recognition of these services by scientists, conservationists, and policy makers, these spaces in many urban areas face pressure and threat to their presence. Especially in developing countries where urban green spaces are inadequately managed, and often encroached upon, thus resulting in loss of quality. While local authorities have historically been responsible for managing urban green spaces, lately there is an increased involvement of citizens in green space management. It is therefore relevant to study how citizens contribute to managing these spaces and ensure their continuity and quality. The study here follows the Open Space Strategic Management approach, described as a complex process comprising of three different levels: strategic–formulation of policy, objectives, and targets; tactical– formulation of time bound plans; and operational–actual actions on these plans to maintain and upkeep the space. The conceptual approach has been operationalised to the area of East Delhi, citing Resident Welfare Associations (RWAs) as a working example of the citizen organisation responsible for green space management. The research specifically focuses on the operational level and tries to explore their contribution towards the maintenance of these spaces. For this purpose, interviews were conducted with the presidents of these organizations (N=34), and information was collected about the actions undertaken by RWAs that constitute as green space maintenance, and their subsequent perceived influence on the green space quality. The findings suggest that for East Delhi, action such as arrangement of financial support in taking care of the local space is a major contribution by the RWAs that have higher influence on the perceived quality of space in terms of being visually appealing. Other actions such as providing guidance, raising up park related issues, and manual help have selective effect on the space being perceived as of good quality in terms of aspects such as user safety, cleanliness in the park space, and in creation of recreational opportunity in the green space for all users. The results from this study will contribute towards the body of literature on role of local citizens and citizen organizations taking part in management of smaller green spaces. The outcomes of this study can be utilized for recommending a comprehensive participatory strategy and design guidelines for green space management in the study area, especially for smaller spaces such as neighborhood parks. This should also contribute towards creation of knowledge to work towards achieving safe, inclusive, resilient, and sustainable green spaces as mentioned in UN Sustainable Goal 11, and the New Urban Agenda.:1. Introduction 3 1.1. Background 3 1.2. Problem 5 1.3. Structure of the thesis 8 1.4. Intended audience 9 2. Literature Review 11 2.1. Urban Green Spaces 12 2.1.1. Multi-functionality of Green Spaces: Ecosystem Services 24 2.2. Green Spaces and the New Urban Agenda 26 2.3. Green Spaces in Delhi- planning and design 29 2.3.1. Planning: Master Plan of Delhi 30 2.3.2. Design: CPWD landscape guidelines 40 2.3.3. The Delhi Preservation of Trees Act, 1994. 41 2.3.4. Gaps in provision 41 2.4. Urban Green Space Management 42 2.4.1. Global Management approaches 42 2.4.2. Green Space Management in Delhi 49 2.5. Theoretical framework 52 2.5.1. Maintenance of green spaces 53 2.6. Summary of the chapter 57 3. Research Hypothesis 59 3.1. Working hypotheses 61 4. Study Area 65 4.1. East Delhi District 68 4.1.1. Civic Boundaries 68 4.1.2. Colony Structure 70 4.1.3. Land Use Pattern 73 4.2. Target group 75 4.3. Summary of the chapter 78 5. Methodological Approach 79 5.1. Survey Interviews 79 5.2. Sampling 80 5.3. Questionnaire Design 82 5.4. Data collection 83 5.4.1. Field work preparation 83 5.4.2. In the Field 84 5.5. Data Analysis 85 5.6. Validity, Reliability and Objectivity of results 86 5.7. Limitations 87 5.8. Summary of the chapter 89 6. Results 91 6.1. Descriptive results 91 6.1.1. Age Category 91 6.1.2. Work Situation 92 6.1.3. Highest level of education received 93 6.1.4. RWA functioning 93 6.1.5. Preferred way of contribution to the maintenance process 97 6.1.6. Preferred reason for involvement in the maintenance process 100 6.1.7. Perceived condition of the local green space 102 6.1.8. Perceived condition of their local green space in terms of safety 106 6.1.9. Desired Improvements to the local park 109 6.2. Hypothesis Testing and Measure of Association 112 6.2.1. Functionality of the equipment for creation of recreational opportunity 112 6.2.2. Cleanliness 115 6.2.3. Upkeep of vegetation 118 6.2.4. Safety 120 6.2.5. Perceived quality 123 6.3. Summary of the results 125 7. Discussion 129 7.2. Resident Welfare Association an example of active citizenship 129 7.3. RWA as a care taker of the local green spaces 131 7.4. Influence of RWA actions on the local green space 135 8. Conclusion 137 8.1. RWA perspective to maintenance 137 8.2. Implications for Green Space Development 139 8.3. Future Research 143 8.4. Theoretical Implications 144 8.5. Contribution of this thesis 146 8.5.1. Contribution to gap in literature 146 8.5.2. Contribution to Landscape Architecture 147 8.5.3. Contribution to Policy Development 147 9. Bibliography 149 Appendix A: Questionnaire 175 Section A: Description of Resident Welfare Association 175 Section B: Involvement in maintenance of local green spaces 177 Section C: Outcomes of RWA actions and activity on the quality of local green space 180 Appendix B 185 Invite 185 Support Letter 186 Appendix C 187 Table depicting administrative structure in territory if Delhi 187 Civil Society in Delhi: Bhagidari 188 Appendix D: Maps of sub areas under East district 189 Appendix E: Examples of Citizen Participation in other cities in India. 191 Appendix F: Statistical Test Values 193 Appendix G 198

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