This paper reports on a study of the tax treaty policy of a group of eleven East African countries. African tax treaties tend to follow one of two model treaties, an OECD model treaty that favours the interests of capital exporting nations and a United Nations model treaty that allows capital importing countries to retain more taxing rights. The study compares the policy outcomes in treaties signed by these countries with African nations, with relatively wealthy OECD countries, and with non-African countries that are not members of the OECD. It also compares selected outcomes in African-OECD treaties with those results in treaties between a group of Asian countries and OECD members to see whether African countries have been more or less successful at wringing preferences from wealthier nations. The study suggests the African countries studied have not been as successful in retaining taxing rights in treaties with OECD countries as have Asian countries. On the other hand, OECD countries are often more generous to African countries than are other African countries. (authors' abstract) / Series: WU International Taxation Research Paper Series

Die gevolge van 'n belastingpligtige se handelinge word binne die belastingreg beoordeel aan die hand van verskillende maatstawwe. Die maatstaf van doel word deur die Wetgewer by die klassifikasie van die belastingpligtige se handelinge by die toepassing van verskeie belastingreëls voorgeskryf. Die howe het oak by geleentheid die maatstaf van doel by die interpretasie van verskeie belastingreëls, waar dit nie uitdruklik voorgeskryf is nie, toegepas. Verskeie vertakkinge van die reg onderskei tussen motief, doel en bedoeling wannear die maatstaf van doel of bedoeling toegepas moet word. Hierdie begrippe is by die interpretasie van verskeie belastingreëls, waar die toepassing van die maatstaf van doel voorgeskryf word, ingevoer. Sommige kenners meen dat 'n soortgelyke onderskeiding nie in die belastingreg tuishoort nie. Die doel van hierdie ondersoek was om, met verwysing na die betekenis en toepassing. van die begrippe, motief, doel en bedoeling in ander regsvertakkinge, die betekenis en toepassing daarvan in die Suid-Afrikaanse belastingreg vas te stel. Met ander woorde, die ondersoek behoort aan te toon of 'n onderskeiding tussen motief, doel en bedoeling in die belastingreg toegepas word, en indien dit nie toe gepas word nie, of dit wei nuttig toegepas kan word. Verder is gepoog om die beperkings van en noodsaaklikheid vir die toepassing van die maatstaf van doel in die belastingreg vas te stel. Dit blyk uit die ondersoek dat die toepassing van die maatstaf van doel by die toepassing van bepaalde belastingreëls nag nie gesuiwer is nie en dat dit lei tot regsonsekerheid en onbillikheid. Verder blyk dit duidelik uit die ondersoek dat die toepassing van die maatstaf van doel wei gesuiwer kan word deur die betekenisse van die begrippe, motief, doel en bedoeling te onderskei en gevolglik korrek toe te pas. In die laaste plek toon die ondersoek aan dat die toepassing van die maatstaf van doel in die belastingreg deur verskeie faktore beperk word, maar dat die toepassing daarvan om verskeie redes noodsaaklik is. Daar word aanbeveel dat die Wetgewer kennis moet neem van die betekenisse van die begrippe motief, doel en bedoeling en 'n vermenging daarvan by die formulering van belastingreëls moet vermy. Dit sal 'n bydrae lewer tot eenvoudiger interpretasie van die betrokke reëls asook 'n meer korrekte toepassing daarvan op die handelinge van die belastingpligtige. Verder behoort die howe nie die onderskeiding van motief, doel en bedoeling by die toepassing van die maatstaf van doel, by die uitleg van belastingreëls te vermy nie. Dit sal onsekerheid en onbillikheid met betrekking tot die toepassing van die betrokke reëls verhoed. ENGLISH : The Income Tax Law in South Africa requires that a taxpayer's actions or transactions are to be classified Qudged) with reference to various criteria. The Legislature requires the application of the criterium of purpose to classify a taxpayer's activities and transactions in terms of various tax rules. Even the Courts applied the criterium of purpose in the interpretation of various tax rules where the criteria has not been specifically required by the legislature. Various branches of the law distinguishes between motive, purpose and intention where the criteria of purpose or intention are required to classify activities. The study indicated that various learned writers are of the opinion that a similar distinction cannot be applied in the Income Tax Law of South Africa. The purpose of this study was to determine the meaning of motive, purpose and intention within the South African Income Tax Law by studying the meaning of the words as they are used in other branches of the law. In other words, the result of the study should indicate whether a similar distinction between motive, purpose and intention is applied in the Income Tax Law and if not, whether such a distinction can be applied in the Income Tax Law. Furthermore, the limitations and necessity of the application of the criteria of purpose in the Income Tax Law was determined. The study indicated that the application of the criterium of purpose in the interpretation of various tax rules had not been clearly distinguished and defined. This fact leads to uncertainty and unfairness in the application of these tax rules. It also became apparent that the application of the criteria of motive, purpose and intention could be more clearly defined and distincted in order to lead to more certain and fair application of income tax rules. Lastly, the study indicated that the application of the criteria of purpose and intention in the Income Tax Law are being limited by various factors but that the application thereof in the Income Tax Law are, because of various reasons, inevitable. It is proposed that the Legislature must take cognisance of the meaning of the criteria of motive, purpose and intention in other branches of the law and that the correct distinction in the formulating of tax rules must be applied. This will contribute to a more just interpretation of the various tax rules as well as a more proper application thereof in the classification of the taxpayer's actions or transactions. Furthermore, it is proposed that the Courts, in the interpretation of the various tax rules, should not avoid to distinguish between motive, purpose and intention. This will have the result that uncertainty and unfairness will be reduced in the application of the various tax rules. Copyright / Dissertation (MCom)--University of Pretoria, 2012. / Auditing / Unrestricted

Please read the abstract in the section 00front of this document / Dissertation (MEd (Education Management))--University of Pretoria, 2005. / Education Management and Policy Studies / unrestricted

This study is about economic diplomacy of China in Africa. It describes development of China-Africa relations, their current form and examines, whether less democratic countries trade more with China than the democratic ones. The study is divided into four chapters. The first one defines economic diplomacy theoretically. The second one focuses on China-Africa relationship from its history up to establishing of Forum on China-Africa Cooperation. It also describes motives of China-Africa cooperation, stressing China's energy dependance. The third chapter describes development of China-Africa trade, Chinese foreign direct investments and development aid and pros and cons of China's presence in Africa. The last chapter examines relationship between level of democracy in african countries and their trade with China.

This thesis discuss the relations of the world superpowers (USA, USSR, China and the EU) with the developing countries in Africa since colonialism until present.

The significance of India in the international system has been increasing not only because of its fast economic development. As one of the manifestations of India's growing position can be considered the expanding of interests to African continent, which is the pivotal topic of this diploma thesis. The presence of India in Africa and its foreign policy towards this continent was analyzed on the basis of the method of four level analysis, which means foreign policy of India towards Africa is examined on levels of international system, state, domestic influences and individuals. To show the position of India in Africa in full context the part comparing its activities with another Asian economic power -- China - is included.

A topic sino-african relations is in a Czech literature overlook. An idea that there are only few reasons for which China and Africa should maintain some important relations is misconception. The sino-african relations have a sixty years long history from a help during the national wars for independence, ideological belongings to a current economic cooperation which reflects a chinese industrial need for raw materials. The economic cooperation lays on a political agreement, an investment activity and a vast aid provided. Chinese demand for african raw materials increses revenue of african countries which are abundant in demanded raw materials and accelarate their development. Through all chinese statements it uses its stronger position against disunited african states which still look for a way how to gain from the sino-african cooperation in the future. China turns a blind eye and ignore critical situations in some african states and misuse non-democratical groups there for its own benefit. At the same time it is clear that it cannot long forever. China will have to participate in solving african problems to protects its own matters there.

The China-African relations have a tradition of several centuries. However, in last two decades, the character of their relations changes and is getting the dimension of a phenomenon. Currently, China is in a very advantageous position - one leg in the developing world, the other in the developed one. Its economic growth reaches about ten percent a year and its economy has enlarged beyond the state's frontiers. China thus becomes dependent on the international trade in both export and import of sources. The African continent can offer both. This situation, however, is hardly compatible with the role of a superpower which China desires and which is attributed to it by many specialists. This thesis analyses three motives of mutual cooperation - commerce, raw materials and political and strategic interests. Its aim is to give a compact and comprehensive picture which will prove the trueness of the three motives. For better accession and understanding, case studies of selected countries are an integral part of the thesis.

The aim of this diploma thesis is to describe historical development of Kenya, analyze its current socioeconomic and political situation and characterize major problems and comparative advantages, which are crucial for its future development. The main contribution of the thesis are my own findings and experience gained during cultural internship in Kenya. The first chapter describes historical development from the beginning of the first settlement on its territory to post colonial era. The second part focuses on demographic indicators, sectorial economic structure, development of macroeconomic indicators in the context of east Africa, political situation and on governmental program called Vision 2030. The last part characterizes key Kenyan advantages and problems with focus on tourism, education and political and religious conflicts. The thesis is closed with future economic prognoses for Kenya.

There has been a significant upsurge in the Sino-African economic cooperation from the turn of the century. The master thesis analyzes the impacts of the growing role of China in the Sub-Saharan region in an attempt to determine, if it contributes to economic growth and development of the regional economies. In order to unpack the potential outcomes of the expanding Sino-African economic cooperation, Chinese trade and outward foreign investment are analyzed in terms of structure, dynamics and geographic distribution. Where possible, the thesis provides a comparison with the practices of the traditional partners, mainly Western European countries and the United States, in order to determine, if China represents a genuinely different partner that contributes to development of the region, or its activities are no more than a mere continuation of the little successful practices of the traditional partners. As the motives of the Chinese presence in the continent have considerably changed over time, the thesis concentrates on the period of 2000s, providing an insight into most significant changes that have come with the Chinese 'going-out' strategy initiated in 1999. Finally, the thesis tries to identify the potential global outcomes of the intensifying South-South cooperation.