[This] dissertation is dedicated to this attempt of making South Africa a more environmentally sustainable economy through the development of new CDM projects. This dissertation examines the introduction of section 12K in the Income Tax Act 58 of 1962 and how this novel incentive interacts with our current income tax legislation. This dissertation highlights some issues surrounding the section 12K exemption which may detract from its true potential and proposes ways to resolve these issues in order to make this incentive more attractive to the CDM project developers.

Despite being internationally recognised as an economic powerhouse of the African continent, South Africa struggles to overcome certain socio-economic problems, which predominantly stem from the inequalities within its society. One of the most important areas of prevailing concern is high unemployment, particularly amongst the youth segment of the population. Approximately 42% of South Africans under the age of 30 are unemployed, a fate shared by less than 17% of those above 30 years of age. The South African government appropriately sought to ensure a better future for all its citizens by 'creating', or facilitating the creation, of more jobs. As part of its 'program of action', one of the initial steps was to enact the Employment Tax Incentive Act, No. 26 of 2013 ('ETIA'). The following extract is from the Explanatory Memorandum on the Employment Tax Incentive Bill, 2013: "High youth unemployment means young people are not gaining the skills or experience needed to drive the economy forward. (…) In response to the high rate of youth unemployment, government wishes to implement an incentive mainly aimed at encouraging employers to hire young and less experienced work seekers, as stated in the National Development Plan. The incentive is one among many that will fall under the umbrella of government's youth employment strategy, the National Youth Accord, which outlines a program of action to address youth unemployment." The primary aim of this study is to conduct a detailed analysis of the ETIA in order to ultimately evaluate its merits, i.e. by expressing an opinion on whether or not it is assisting in combatting youth unemployment. The analysis compares similar types of legislation that have been implemented, both successfully and unsuccessfully, in other countries in attempts to address similar unemployment issues. This paper reflects events, legislation and published literature as at 1 December 2015.

Includes bibliographical references (leaves 114-120). / Increased globalisation has lead to centralised risk management and decision-making in multinational enterprises, which gives rise to the principle of tax efficient supply chain management and the need to focus on the integration of tax considerations into the multinational's supply chain. In order to retain a competitive advantage in the global economy, multinational enterprises need to constantly search for cost benefits. This has created a market for tax motivated structures and the consequential action by tax authorities world-wide to regulate transfer pricing, in order to protect their respective tax bases. As revenue authorities increase their focus on transfer pricing compliance, it is vital that multinationals adhere to the arm's length principle and ensure their transfer pricing documentation can substantiate the transfer prices selected.

The Cuban Medical Training program is an initiative that provides bursaries to international students from disadvantaged backgrounds. Understanding the experiences of South African participants, particularly those who complete their transitional component at University of Cape Town (UCT), and how they are prepared to meet the aims of the South African-Cuban Medical Training Program (SACMTP), the needs of their local communities, and ultimately, the needs of the South African health system, is the focus of my research.

Includes abstract. / Includes bibliographical references. / The purpose of this study is to test whether or not the lowering of the corporate tax rates and/or the exemption from corporate taxes for manufacturing companies in the SADC region are indicative of member states endeavouring to achieve a common approach to the treatment and application of tax incentives and simultaneously avoid harmful tax competition.

Includes bibliographical references. / Many of the countries in sub-Saharan Africa are classified within a sub-category of developing countries referred to as frontier economies. These economies are producing growth rates that often surpass both the more advanced developing countries such as China, as well as the growth rates of the developed world. This study evaluates the investing landscape in Africa, with particular focus on the countries of Ghana and Rwanda. An in-depth analysis of each country’s taxation system and the areas within those systems that may affect the foreign direct investment decision is undertaken. The study then goes on to compare each of the respective country’s taxation laws and policies, specifically in regard to taxation incentives, to the laws and policies currently applicable in South Africa. This is performed with the aim of investigating possible improvements that may assist in enlarging the selected country’s taxation revenue. Further, it is also the intent of this study that the solutions proffered for the improvement of the policies and regulations currently in place will assist in increasing the transparency with which the systems operate. When taken in unison these suggested amendments would sanguinely work towards enhancing the overall experience of investors – both domestic and foreign.

Includes bibliographical references (leaves 74-76). / Solutions to the proven threat of climate change have attracted a vast amount of attention as evidenced by the convention on Climate Change hosted by the United Nations in Copenhagen very recently. But this was only the most recent in a series of conventions, treaties and other forms of agreements entered into in an attempt to stop the climate change effect from spiralling out of control. However, in the wake of such conferences a harsh question remains, how many of the proposed action plans are just those: plans? A plan is no more than a formalized thought until it is implemented and the effects thereof are tangibly observable to the general populace. Most importantly though is the factor of time. The planet cannot afford a drawn out and lengthy debate on the merits of the threats posed by global warming and then only contemplate possible resolutions to the threats so agreed to. Action needs to be taken immediately, and the action plans designed and implemented need to be effective without delay. Two of these tangible solutions that have been proposed are those of setting carbon emission caps and subsequently granting credits so as to facilitate a trading of these credits, namely the ‘cap and trade’ approach, and the other is that of legislating and implementing a carbon tax. Variations of both of these systems have been implemented by individual countries the world over with varying levels of success However, as one looks to the future; there is no consensus on a global solution to what is very much a global problem.

Includes bibliographical references (leaves 57-60). / The taxation of international partnerships has particular relevance for South Africa. Zaaiman (2008:5) remarks that South African investors often have limited choice in the legal form of the entity in which they invest. Their lack of choice largely stems from the fact that the type of legal structure implemented internationally is shaped by the tax and commercial concerns relevant to the foreign jurisdiction in which such structure is established (Zaaiman, 2008:5). In South Africa, the taxation of partnerships has received very little attention. There is also no legislation in place dealing with this business vehicle. However, many South Africans are investing in offshore partnerships. There is accordingly a need to develop a comprehensive work on the taxation of cross-border partnerships. Furthermore, on a domestic level, the recent judgment delivered in Grundlingh v CSARS raised several issues regarding the taxation of cross-border partnerships. Of particular relevance to the common law of South Africa, is the yet unresolved tension which now seems to exist between the Grundlingh case and the well-established principles of the taxation of international partnerships as laid down by the then Appellate Division in the CIR v Epstein judgment. The comments made regarding partnerships in the CIR v Lever Bros3 judgment also seems to conflict with the Grundlingh case. Bearing in mind the principle of stare decisis and the constitutional obligation to develop South African common law in line with international law, it is necessary that a body of work be developed to begin the process of reconciling South African sources of law into one coherent approach, to the taxation of cross-border partnerships.

In February 2013, the OECD published a report on its findings concerning base erosion and profit shifting ("BEPS").1 That report, in particular Action Plan 13, dealt with the re-examination of transfer pricing documentation wherein the shifting of profits to lower tax rate jurisdictions is addressed. The OECD proposed a Country-by-Country ("CbC") methodology whereby certain information is required to be disclosed within a Country-by-Country Reporting Template ("the CbC Template"). The main purpose of the CbC Template is to assist tax administrations to identify risks related to base erosion and profit shifting; also, and where applicable, data collected via the CbC Template can be used for economic and statistical analysis. The OECD is of the view that the CbC Template in assisting tax administrators to determine transfer pricing risk, will serve as a high-level risk assessment indicator for transfer pricing. Accordingly, the main aim of the CbC Template is to be a tool for tax administrators to identify and consequently ensure that the revenue of a country is not eroded unfairly. The objective of this paper is to review the CbC Template from a South African perspective and to determine the consequences for taxpayers arising from the information required to be disclosed. It follows that this paper will focus, in particular, on the challenges and consequences that exist within a South African context for a South African taxpayer conducting business in different tax jurisdictions. The paper will further analyse the CbC Template requirements in light of the legislative requirements for Transfer Pricing Documentation in South Africa.

Includes abstract. Includes bibliographical references (leaves 65-70).