With constant changes in the nature of businesses, the way businesses are managed and the manner in which corporate groups are structured, a valid risk exists that legislation, including controlled foreign company (CFC) legislation can become outdated. The implication is that a country’s tax base will not be effectively protected. The aim of this mini-dissertation is to analyse section 9D of the South African Income Tax Act (58 of 1962) against the United Kingdom’s CFC regime to identify aspects of the new CFC rules enacted in Great Britain that could enhance South African CFC rules. Since the United Kingdom and South Africa levy income tax on a residence basis, it was concluded that the CFC regimes of these countries would be comparable. The research problem statement was determined to consider whether any aspects of the amended United Kingdom CFC legislation could be incorporated in the South African CFC rules to ensure that they are more accommodating to investors on the one hand and still protect the South African tax base efficiently on the other hand. The problem statement was addressed through the research objectives. Their findings are summarized as follows: 1 To determine what the factors and circumstances were that resulted in the revised CFC legislation in the United Kingdom. It was found that the Commissioner of Inland Revenue was applying the “motive test” very subjectively which resulted in resident-holding companies being taxed on legitimate trading profits of foreign subsidiaries. The “motive test” therefore lacked objectivity which resulted in the residents being taxed on the profits of their subsidiaries. Since section 9D of the South African Income Tax Act (58 of 1962) also applies a subjective test to consider the investor’s motives, it was concluded that the South African legislation is faced with a similar pitfall as the UK CFC legislation enacted in 1984. 2 To critically compare the CFC rules per section 9D of the South African Income Tax Act to the CFC legislation effective 1 January 2013 in the United Kingdom. It was found that the South African rules address a wider range of activities, whereas the UK CFC regime focuses on specific income streams. A number of aspects were identified where the two sets of legislation agree, but areas were also identified where the legislation differs. 3 To identify elements of the new CFC legislation in the United Kingdom that might improve the current South African CFC regime. The differences identified between the South African and United Kingdom CFC regimes were evaluated. It was concluded that there are elements of the South African legislation that should remain unchanged as it addresses specific risks. It was, however, also concluded that there are valid elements implemented in the UK CFC regime that could simplify the South African CFC legislation, enhancing its competitiveness while still retaining the integrity and effectiveness of the legislation. It was concluded that even though the differences between section 9D and the UK CFC regime may enhance section 9D when enacted in South Africa, these enhancements should be considered very carefully as they might create loopholes providing false progress to section 9D. / MCom (South African and International Taxation), North-West University, Potchefstroom Campus, 2014

With constant changes in the nature of businesses, the way businesses are managed and the manner in which corporate groups are structured, a valid risk exists that legislation, including controlled foreign company (CFC) legislation can become outdated. The implication is that a country’s tax base will not be effectively protected. The aim of this mini-dissertation is to analyse section 9D of the South African Income Tax Act (58 of 1962) against the United Kingdom’s CFC regime to identify aspects of the new CFC rules enacted in Great Britain that could enhance South African CFC rules. Since the United Kingdom and South Africa levy income tax on a residence basis, it was concluded that the CFC regimes of these countries would be comparable. The research problem statement was determined to consider whether any aspects of the amended United Kingdom CFC legislation could be incorporated in the South African CFC rules to ensure that they are more accommodating to investors on the one hand and still protect the South African tax base efficiently on the other hand. The problem statement was addressed through the research objectives. Their findings are summarized as follows: 1 To determine what the factors and circumstances were that resulted in the revised CFC legislation in the United Kingdom. It was found that the Commissioner of Inland Revenue was applying the “motive test” very subjectively which resulted in resident-holding companies being taxed on legitimate trading profits of foreign subsidiaries. The “motive test” therefore lacked objectivity which resulted in the residents being taxed on the profits of their subsidiaries. Since section 9D of the South African Income Tax Act (58 of 1962) also applies a subjective test to consider the investor’s motives, it was concluded that the South African legislation is faced with a similar pitfall as the UK CFC legislation enacted in 1984. 2 To critically compare the CFC rules per section 9D of the South African Income Tax Act to the CFC legislation effective 1 January 2013 in the United Kingdom. It was found that the South African rules address a wider range of activities, whereas the UK CFC regime focuses on specific income streams. A number of aspects were identified where the two sets of legislation agree, but areas were also identified where the legislation differs. 3 To identify elements of the new CFC legislation in the United Kingdom that might improve the current South African CFC regime. The differences identified between the South African and United Kingdom CFC regimes were evaluated. It was concluded that there are elements of the South African legislation that should remain unchanged as it addresses specific risks. It was, however, also concluded that there are valid elements implemented in the UK CFC regime that could simplify the South African CFC legislation, enhancing its competitiveness while still retaining the integrity and effectiveness of the legislation. It was concluded that even though the differences between section 9D and the UK CFC regime may enhance section 9D when enacted in South Africa, these enhancements should be considered very carefully as they might create loopholes providing false progress to section 9D. / MCom (South African and International Taxation), North-West University, Potchefstroom Campus, 2014

This thesis examines the efficacy of markets, using both quantitative and qualitative methods in a complementary way. Specifically, it starts (in Part II) by using the results from a quantitative analysis of initial public offering (IPO) underpricing as a barometer for corporate governance failure. This quantitative work identified Russia, China and India as extreme outliers. The data set used for this work was the cross-section sample of 45 countries developed by Loughran, Ritter & Rydqvist (2008). More broadly (in Part III), the thesis takes the lead of the quantitative evidence to examine, in a qualitative framework, possible sources of corporate governance failure in China, India and Russia. This was done categorically, under the headings of Globalisation, Corporate Governance, Institutional Structure and Competitive Strategy. Data were gathered by eldwork in China, India and Russia, and these findings were then benchmarked against findings from further fieldwork in the United Kingdom. This created a unique 56,000 word database, which was used for both cross-site and within-site analysis. This indicates how both unique attributes (e.g. rule of law, transparency, regulation, etc.), and common attributes (e.g. transition from a socialist/Marxist regime, market immaturity, asymmetric information etc.), combine to explain the different morphologies of corporate governance in these three countries. The quantitative analysis (Part II) consists of exploratory data analysis (EDA) and econometric work. The exploratory data analysis establishes, through graphical means and regression techniques, a negative correlation between IPO underpricing and globalisation (as measured by the KOF index, see Dreher, 2006). Building on this, the subsequent econometric modelling suggests that economic, demographic and institutional factors are all significant determinants of IPO underpricing. The qualitative analysis carried out in Part III of the thesis, builds on and extends the quantitative analysis of Part II. This is consistent with the multiple method approach, which combines both quantitative and qualitative analysis to achieve a synthesis of findings. The qualitative analysis uses evidence from semi-structured interviews with finance professionals and opinion makers, as well as evidence from additional primary and secondary sources, which was also made available through fieldwork contacts. This analysis emphasises the especial importance of board composition, information flows, the judicial system, the stock exchanges, and financial regulators for forms of corporate governance.

Construction activity is known to have a major impact on the environment and is a major consumer of a wide range of naturally occurring and synthesized resources. Despite the recognition that environmental issues are important to the survival of the construction industry, the industry continues to degrade the environment, exploiting resources and generating waste, and is slow to change its conventional practices to incorporate environmental matters as part of its decision making process. With increased awareness and knowledge of these impacts, efforts are being made to avoid these adverse effects and to work towards impact mitigation. Among these is sustainable building material selection. Building material selection is an important issue in building design and construction decision-making and environmental issues need to be incorporated into the evaluation process. The research reported in this thesis was initiated to address these issues in the UK, towards developing an assessment model for incorporating sustainability into building material selection process. A questionnaire survey was conducted to investigate the level of awareness, knowledge and implementation of sustainable practices among architects and designers and how this impacts on their design decisions. To facilitate the implementation of sustainable practices into building material selection, a set of sustainable assessment criteria (SAC) for modeling and evaluating sustainability performance of building materials was developed. Building material can be assessed using an index system that combines the principal criteria of sustainable development. The derived criteria were assessed and aggregated into a composite sustainability index using the Analytical Hierarchy Process (AHP) technique which has been praised for its ability to incorporate both objective and subjective considerations in the decision process. The development of a sustainability index is a way of supporting decision makers faced with making numerous and sometimes conflicting evaluation as with building material selection. The methodology adopted in undertaking this research was the mixed method approach involving a detailed review of the relevant literature, followed by an industry-wide survey of UK architects and designers. Following this, case study was conducted to collect data for sustainability criteria used in the assessment model. The data collected were analyzed, with the aid of SPSS, Excel and expert choice software using a variety of statistical methods including descriptive statistics analysis, relative index analysis, Kendall’s concordance and factor analysis. The key finding was the existing gap between awareness and implementation of sustainable construction practices, which has led to failure of realizing the benefits of a sustainable approach to construction. The study showed a discrepancy between what architects and designers claim to be convinced about, and knowledgeable in, and their commitment and practices; they seem to be unable to translate their environmental awareness and knowledge into appropriate design decisions and are in need of a decision support system that can aid the incorporation of sustainability into building design. The model developed satisfy this gap and was validated by application to a roof covering material selection decision process for a case study building project by means of experts’ review via a survey and the findings obtained suggest that the model is valuable and suitable for use in practice. Finally, areas for further research were identified.

Electronic procurement (e-procurement) has been widely adopted across the private sector, and as such various aspects of its adoption has been researched. The adoption of e-procurement in the public sector is not as widespread, especially in relation the UK Central and Local Government sectors, and accordingly there has been limited research into the factors affecting the adoption of e-procurement technologies, within this context. Consequently, this study, which has been undertaken with five case study organisations spread across the UK Central and Local Government sectors, aims to add to current published literature, and in particular provide an understanding of the relationship between the factors identified which have affected adoption, and the extent of adoption of e-procurement solutions. This research provides a number of significant contributions to current published literature including a comprehensive definition and conceptualisation of e-procurement and a holistic research framework which facilitates understanding the relationships between the level of adoption by the case study organisations and the factors affecting their decisions. Additionally, this study demonstrates that there is a high degree of commonality between the case study organisations in terms of their levels of adoption, and the factors that have affected such adoption. Of these factors, there are four that are particularly important, as they haven't previously attracted much attention in the literature. More specifically, this research highlights the importance of understanding an organisation's procurement landscape, the impact (both negative and positive) of public policy on adoption, the impact of enhanced organisational standing and the need for vision and leadership from senior stakeholders.

Honour killings are considered by the perpetrators the only path to maintain theirs and their family honour, preventing other's to follow behaviours that move away from traditional patriarchal values. With the aim of exploring how honour killings are characterised, a qualitative study within three European newspapers, in three different languages, was conducted. The findings showed that often the victims are characterised as young women and girls that want to live independently from their birth cultures or that acted in a way considered to be a dishonour to their family culture. Perpetrators are often described as family members, mostly males to whom honour is worth more than life. However, some of the news articles launch the debate of the thin line that divides honour crimes and domestic violence making this not a cultural problem but a widespread cross-cultural reality.

This thesis challenges the conventional wisdom that the W.S.P.U.'s strategy choices were unimportant in regard to winning women's suffrage. It confirms the hypothesis that the long-range strategy of the W.S.P.U. was to escalate coercion until the Government exhausted its powers of opposition and conceded, but to interrupt this strategy whenever favorable bargaining opportunities with the Government and third parties developed. In addition to filling an apparent research gap by systematically analyzing these choices, this thesis synthesizes and tests several piecemeal theories of social movements within the general framework of the natural history approach. The analysis utilizes data drawn from movement leaders' autobiographies, documentary accounts of the militant movement, and the standard histories of the entire British women's suffrage movement. Additionally, extensive use is made of contemporary periodicals and miscellaneous works on related movements.

Chenopodium album is considered one of the most important weeds adversely affecting agricultural production due to its highly competitive influence on field crops. Chemical herbicides have increased the efficiency of farming, but recently problems of herbicideresistant weed populations and herbicide residues in soil, water, food products and effects on non-target organisms have increased, consequently, other methods of control of weeds by using specific fungi as herbicides have been suggested. The purpose of this research was to evaluate the biological control of the weed Chenopodium album by the fungus Ascochyta caulina. Some of the factors which control dormancy and germination of Chenopodium album seeds have been investigated to understand better the weed population dynamics. The results showed that seeds from two populations (UK and Libya) differ in their response to factors such as light, chilling, and burying in soil. This could have implications for effective control of the weed in different regions. Two formulations of mycoherbicides (Tween 80 and Gelatine based applications) were tested in the laboratory, and showed promise in reducing growth of the weed, especially the formula of Tween 80. There was extensive shoot fresh and dry weight reduction of inoculated Chenopodium album, as well as reduced root growth. Highest disease severity rates were observed on plants in the first three week of life. A field trial revealed similar results but less disease severity was observed, possibly because of dry weather. However, it was concluded that the fungus Ascochyta caulina is a potentially useful biological control agent but many factors still can be modified in relation to application of the mycoherbicide to increase its efficacy.

The recent collapse of the Dublin system, a system meant to distribute responsibility towards asylum-seekers and refugees between EU Member States (MSs), has marked a new phase of the so-called European Refugee “Crisis”, where the inability of EU MS governments to address the situation in a unified and coherent manner ultimately harms those most in need of protection. Public discontent with EU and MS government responses to the crisis has led to strong citizen mobilisation in the form of civil society. This study focuses on the case of the UK and examines the role played by policy advocacy Civil Society Organisations (CSOs). The concept of Political Responsibility is used to establish the emergence of a Governance Gap in the UK's response to the crisis, where the government finds itself unable to bridge a growing distance between its representation and responsible governance functions. Policy advocacy CSOs are found to be now minding this gap. Critical Discourse Analysis is used to study how CSOs react to the UK government's response in terms of practice and discourse, and to highlight the consequences which language use can have on how we perceive and treat refugees and asylum-seekers in this context.

La France possède une industrie qui en couvre les principales branches, dimensionnée pour faire face aux besoins de la consommation, mais partie avec retard dans la révolution industrielle, elle n’est pas apte à soutenir la concurrence de nations rivales plus avancées; le gouvernement est contraint d’appliquer des mesures protectionnistes pour sauvegarder l’emploi; de nombreuses institutions ont pour but de favoriser le développement du commerce et de l’industrie; mais les Français ont un esprit d’entreprise peu développé; la prudente circonspection des négociants français s’oppose au caractère hardi et aventureux des Anglo-saxons. La Grande-Bretagne s’est dotée, surtout dans le textile, d’un outil de production industrielle innovant et performant, dimensionné pour dépasser largement les besoins du marché intérieur; ses négociants et ses fabricants possèdent un esprit qui les tourne vers le commerce extérieur dans leur recherche de profit; enfin le pays possède des institutions financières solides et une flotte de commerce à laquelle le Navigation Act pris sous Cromwell a permis de donner un grand développement; mais une détresse profonde qui sévit dans les classes laborieuses vient sérieusement ternir ce tableau flatteur. Entre 1822 et 1850 la France voit la production de son industrie manufacturière plus que doubler, son commerce extérieur tripler; elle double la part de marché qu’elle possède dans les exportations de produits naturels et manufacturés au Brésil; cela constitue pour la France une réussite, mais n’aurait elle pas pu mieux faire? La thèse tente d’apporter des éclairages sur les responsabilités relatives de la politique suivie par le gouvernement et du comportement des acteurs privés. / The French industry covers the main branches of which it is composed, and is designed to cope with the consumption of the country; but having started tardily it cannot withstand the competition of more advanced rival nations; the government has to promote protectionist measures to safeguard employment; numerous institutions exist to boost the development of trade and industry; but French people lack the spirit of enterprise; the prudent circumspection of French merchants is opposed to the bold and adventurous character of Anglo-Saxons. Great Britain has developed, mainly in their textile industry, an innovating and performing tool for industrial production, designed to exceed considerably the needs of domestic market; the merchants and manufacturers have a spirit oriented toward international trade to make a profit; and the country has solid financial institutions and a merchant shipping to which the Navigation Act promulgated by Cromwell gave a big advantage; but a big distress which exists in the working classes tarnishes this flattering landscape. Between 1822 and 1850 the production of French industry more than doubled, the foreign trade tripled; and its market share for exports of natural and manufactured products to Brazil doubled; this was a success for France, but could she have done better? The thesis tries to throw some light on the comparative responsibilities of the governmental policies and the behaviour of the private sector.