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Evaluating value based financial performance measuresErasmus, Petrus Daniel 03 1900 (has links)
Thesis (PhD (Economics))--University of Stellenbosch, 2008. / The primary financial objective of a firm is the maximisation of its shareholders’
value. A problem faced by the shareholders of a firm is that it is difficult to determine
the effect of management decisions on the future share returns of the firm.
Furthermore, it may be necessary to implement certain monitoring costs to ensure that
management is focused on achieving this objective. A firm would, therefore, benefit
from being able to identify those financial performance measures that are able to link
the financial performance of the firm to its share returns. Implementing such a
financial performance measure in the valuation and reward systems of a firm should
ensure that management is aligned with the objective of shareholder value
maximisation, and rewarded for achieving it.
A large number of traditional financial performance measures have been developed.
These measures are often criticised for excluding a firm’s cost of capital, and are
considered inappropriate to be used when evaluating value creation. Furthermore, it
is argued that these measures are based on accounting information, which could be
distorted by Generally Accepted Accounting Practice (GAAP). Studies investigating
the relationship between these measures and share returns also provide conflicting
results. As a result of the perceived limitations of traditional measures, value based
financial performance measures were developed. The major difference between the
traditional and value based measures is that the value based measures include a firm’s
cost of capital in their calculation. They also attempt to remove some of the
accounting distortions resulting from GAAP.
Proponents of the value based measures present these measures as a major
improvement over the traditional financial performance measures and report high
levels of correlation between the measures and share returns. A number of studies
containing contradictory results have been published. On the basis of these
conflicting results it is not clear whether the value based measures are able to
outperform the traditional financial performance measures in explaining share returns.
The primary objectives of this study are thus to:
• Determine the relationship between the traditional measures earnings before
extraordinary items (EBEI) and cash from operations (CFO), and shareholder
value creation;
• Investigate the value based measures residual income (RI), economic value added
(EVA), cash value added (CVA) and cash flow return on investments (CFROI),
and to determine their relationship with the creation of shareholder value;
• Evaluate the incremental information content of the value based measures above
the traditional measures. The information content of the traditional measures and the value based measures are
evaluated by employing an approach developed by Biddle, Bowen and Wallace
(1997). The first phase of this approach entails the evaluation of the relative
information content of the various measures in order to determine which measure
explains the largest portion of a firm’s market-adjusted share returns. The second
phase consists of an evaluation of the incremental information content of the
components of a measure in order to determine whether the inclusion of an additional
component contributes statistically significant additional information beyond that
contained in the other components. The study is conducted for South African
industrial firms listed on the Johannesburg Securities Exchange for the period 1991 to
2005.
The data required to calculate the measures investigated in the study are obtained
from the McGregor BFA database. This database contains annual standardised
financial statements for listed and delisted South African firms. It also contains EVA,
cost of capital and invested capital amounts for those firms listed at the end of the
research period. Including only these listed firms in the research sample would
expose the study to a survivorship bias. Hence these values are estimated for those
firms that delisted during the period under review by employing a similar approach to
the one used in the database. The resulting sample consists of 364 firms providing
3181 complete observations. Since different information is required to calculate the
various measures included in the study, different samples are compiled from this
initial sample and included in the tests conducted to evaluate the information content
of the measures.
The results of this study indicate that the value based measures are not able to
outperform EBEI in the majority of the relative information content tests.
Furthermore, the measures EVA, CVA and CFROI are also not able to outperform the
relatively simple value based measure RI. The results from the incremental
information content tests indicate that although some of the components of the value
based measures provide statistically significant incremental information content, the
level of significance for these relatively complex adjustments is generally low.
Based on these results, the claims made by the proponents of the value based
measures cannot be supported. Furthermore, if a firm intends to incorporate its cost
of capital in its financial performance measures, the measure RI provides most of the
benefits contained in the other more complex value based measures.
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The influence of cultural factors on successful succession in Indian South African family owned businesses and American family owned businesses (based in Indiana)Taruwinga, Patience 09 1900 (has links)
This doctoral dissertation utilizes survey research design and an interview research design to compare the influence of cultural factors on successful succession in South African and American family owned business (FOB’s). The target populations consisted of owner managers and successors of FOB’s located in two countries: USA (State of Indiana) and South Africa (Indian South Africans). The qualitative research methodology was based on 1:1 interviews with 10 FOB’s in South Africa and the USA. The survey research methodology was based on a cross-sectional survey and the research design was correlational. The independent variables included nine cultural dimensions of the target populations measured using a dedicated survey instrument. The dependent variable (Perceived Success) was the relative success of each participant in the target population, with respect to his/her alleged levels of accomplishment in the succession processes. The demographic characteristics of the members of the target populations were also recorded.
Correlative relationships between nine reliably measured cultural dimensions, seven demographic characteristics, and the Perceived Success of the succession process were identified. Differences between the populations in USA and South Africa were apparent. Multiple Linear Regression analysis indicated that the most important predictor of Perceived Success in the USA population was Performance Orientation, followed in rank order by In-Group Collectivism, Assertiveness, and Uncertainty Avoidance. Demographic variables had no significant effect on the relationship between Predicted Success and the cultural dimensions of the USA population. In comparison the most important predictor of Perceived Success in the Indian South African population was Uncertainty Avoidance, followed in rank order by Performance Orientation, Future Orientation, the age of the participant, and the number of people who worked in the participant’s organization. The combined model between the USA and the Indian South African FOB’s indicated that the most important predictor for perceived success was Uncertainty Avoidance, followed in rank order by In- Group Collectivism, Performance Orientation and Assertiveness. Evidence is provided to conclude that the relative importance of cultural dimensions and demographic characteristics to the succession planning of owner managers and successors in South Africa was significantly different to those of their western counterparts.
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Kwazulu Natal's institutional environment : its impact on development imperatives.Barnes, Justin Raymond. January 1995 (has links)
The study of development in the 1960s and early 1970s was characterised by major struggles between competing ideological positions . Writings were dominated by attempts at getting the ideologies right , hence the proliferation ofNeo-Marxist and Neo-Classical discourses. The vociferous debates between development theorists such as Andre Gunder Frank (1966), Paul Baran (1962), W.W. Rostow (1963) and their followers) were indicative of this period. A fundamental shift occurred in the late 1970s, however, when the focus of development studies shifted to the more technical issue of how to get prices right. World Bank and International Monetary Fund intervention in state affairs were a characteristic of this fundamental shift, with the now notorious Structural Adjustment Programmes (SAPs) of the 1980s being a direct result of this movement. The whole terrain of development studies has once again, however, undergone reconstruction, with the emergence of an entirely new strain of development-oriented thought in the 1990s. The key development problem being identified by social scientists at present is the institutional context in which development takes place. It has finally emerged that this issue surpasses those debates concerning ideology and monetary issues. Development protagonists now acknowledge that they can no longer look at development without considering the institutional environment in which it is to take place. Irrespective of ideology and price factors, then, it has finally been realised that development is highly contingent upon the establishment of a sound development-oriented institutional environment. Although the international development arena has experienced this fundamental shift, very little research has been done , thus far, on the dynamics of KwaZulu Natal 's institutional environment. As such very little is known about its efficacy in supporting or initiating development programmes in the province. If one considers the enormity of the development task in KwaZulu Natal this is an extremely unsatisfactory situation. KwaZulu Natal undoubtedly needs a sound institutional environment that supports development, thus making a study of how the province's institutional environment impacts on development imperatives an extremely important endeavour. It is hoped that this dissertation helps in some small way to fill the research void that is clearly apparent in KwaZulu Natal. It needs to be iterated right at the outset, however, that this dissertation is not meant to be an extensive, all encompassing critique of KwaZulu Natal's institutional environment. It is rather an exploration of those important issues pertaining to its institutional environment that impact so dramatically on development imperatives in the province. / Thesis (M.Soc.Sci.)-University of Natal, Durban, 1995.
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Alignment of supply chain management practices with policies and regulations in state owned entities in South AfricaSetino, Rebecca 06 1900 (has links)
The study examined the alignment of Supply Chain Management (SCM) practices with the policies and regulations in State-Owned Entities (SOEs) in South Africa. SCM plays a crucial role in the implementation of service delivery programmes and the achievement of socioeconomic imperatives in SOEs in South Africa. However, there is a substantial misalignment between SCM practices and the relevant policies and regulations, which negatively influences the performance of SOEs in South Africa. The research study was designed to employ a combination of exploratory and descriptive research, using quantitative approaches based on a survey of SCM managers in SOEs in South Africa. A structured questionnaire was administered to SCM managers who were selected using simple random sampling. Descriptive statistics using the software, SPSS version 21.0, was used for the statistical analysis and to provide the descriptive analysis results. In addition, Smart PLS 2.0 M3 was used for structural Equation Modelling to assess the alignment between the key variables.
The results of the study revealed that, in general, there is an alignment between SCM practices and SCM policies and regulations. However, based on the analysis of the four constructs that were used in the study (SCM strategy, SCM policies and regulations, SCM practices, and SCM performance), the results revealed a misalignment between SCM strategy and SCM performance. The study further revealed a positive and weak relationship between Enterprise Supplier Development (ESD) and SCM performance in SOEs. The poor implementation of these two practices compromises the contribution of SCM to socioeconomic imperatives, and consequently SCM. The results of the five SCM policies and regulations that were examined indicated the poor implementation of Broad-Based Black Economic Empowerment Act (BBBEEA) across SOEs. The study suggests a conceptual framework for SCM in SOEs to enable them to enhance their performance. The study provides an understanding of how SCM could be applied efficiently in the SOEs environment and it provides new insights to the body of knowledge. / Applied Management / D. Admin. (Business Management)
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The transfer of undertakings with specific reference to the transfer of insolvent undertakings - an evolution of the South African lawSpree, Wolfgang 03 1900 (has links)
Thesis (LLM (Mercantile Law))--University of Stellenbosch, 2007. / The freedom to transfer an undertaking is part of the employer’s freedom of contract. The
transferee of an undertaking under the common law has the right to choose whether he wants to
contract with employees or not.
By the implementation of section 197 of the Labour Relations Act (1995) and the amended
sections 197, 197A of the Labour Relations Act (2002) the legislator provides for an automatic
transfer in cases where the undertaking is transferred as a going concern. The former accordance
with the regulations of the insolvency law and the fact that sequestration or the winding-up of an
insolvent undertaking had to be to the advantage of the creditors was lost after the legislative steps
of 1995.
The effects of the above-mentioned sections and especially the problems regarding the transfer of
insolvent undertakings shall be analysed in this thesis. It is the aim of this thesis to examine how
sections 197, 197A of the Labour Relations Act and section 38 of the Insolvency Act should be
applied and interpreted to achieve social justice. This makes it necessary to examine the history
and development of the South African law of transfer of an insolvent undertaking too.
Section 197 of the Labour Relations Act is mostly based on European law. Although it is not the
intention of this thesis to compare the European law with the South African law, several South
African aspects will be examined from a European and especially German perspective.
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Die beoefening van ‘n bedryf met spesifieke verwysing na die toestaan van lenings deur houermaatskappye aan filiale of geassosieerdesMarais, Suzanne 12 1900 (has links)
Thesis (MAcc) -- Stellenbosch University, 2004. / ENGLISH ABSTRACT: In order for a taxpayer to be entitled to a deduction for expenditure actually incurred, the taxpayer must meet the requirements of section 11(a), read with the provisions of sections 23(f) and 23(g).
The preamble of section 11 requires that the taxpayer should incur the expenditure in the carrying on of a trade, before it will be deductible. Therefore, taxpayers who do not carry on a trade will not be allowed any deductions for expenditure actually incurred in terms of section 11(a).
In the case of a holding company that grants loans to its subsidiaries or associates, there is a general prevailing view that the holding company does not carry on a trade in respect of the loans granted. Therefore it is argued that the holding company is not entitled to any deductions in terms of section 11(a).
This study questions the above-mentioned general view by considering case law and the opinions of various tax experts. The question is raised whether the holding company could be regarded as carrying on a trade, and if so, under what circumstances that will be the case.
A secondary issue that will be considered is whether the holding company is entitled to deductions in respect of interest expenditure actually incurred. In this regard a distinction is made between moneylenders and non-moneylenders.
The writer reaches the conclusion that the definition of “trade” is not all-inclusive, and that the Legislator intended that the term should be interpreted as widely as possible. Therefore, the writer is of the opinion that taxpayers who are not moneylenders could, under certain circumstances, be carrying on a trade in respect of the granting of loans and should thus be entitled to income tax deductions for expenditure incurred. / AFRIKAANSE OPSOMMING: Vir ‘n belastingpligtige om op ‘n aftrekking vir uitgawes werklik aangegaan, geregtig te wees, moet aan die bepalings van artikel 11(a), saamgelees met dié van artikels 23(f) en 23(g) voldoen word. Die aanhef tot artikel 11 vereis dat ‘n belastingpligtige die uitgawes in die beoefening van ‘n bedryf moet aangaan voordat ‘n aftrekking gëeis kan word. Belastingpligtiges wat dus nie ‘n bedryf beoefen nie, sal op geen aftrekkings vir uitgawes werklik aangegaan ingevolge artikel 11(a) geregtig wees nie. Met betrekking tot ‘n houermaatskappy wat lenings aan sy filiale of geassosieerdes toestaan, heers daar ‘n algemene siening dat die houermaatskappy nie ‘n bedryf beoefen met betrekking tot die toestaan van lenings nie. Daarom word geargumenteer dat die houermaatskappy nie ingevolge artikel 11(a) op enige aftrekkings geregtig is nie. In hierdie studie word bogenoemde algemene siening krities aan die hand van regspraak en menings van belastingkenners oorweeg. Die vraag word gevra of die houermaatskappy nie wel beskou kan word om ‘n bedryf te beoefen nie, en indien wel, onder watter omstandighede dit so sal wees. ‘n Sekondêre aspek wat oorweeg word, is of die houermaatskappy op ‘n aftrekking vir rente uitgawes werklik aangegaan by die toestaan van die lenings geregtig is. In hierdie verband word ‘n onderskeid tussen geldskieters en nie-geldskieters getref. Die skrywer kom tot die gevolgtrekking dat die omskrywing van “bedryf” nie allesomvattend is nie, en dat dit blyk of dit die Wetgewer se bedoeling was om die begrip so wyd as moontlik te stel. Dit is die skrywer se mening dat belastingpligtiges wat nie geldskieters is nie, wel onder bepaalde omstandighede beskou kan word om ‘n bedryf te beoefen met betrekking tot die toestaan van lenings. Daarom behoort sulke belastingpligtiges wel op inkomstebelastingaftrekkings vir uitgawes werklik aangegaan, geregtig te wees.
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Technical and allocative efficiency in determining organizational forms in agriculture : a case study of corporate farmingDobrowsky, David W. 12 1900 (has links)
Thesis (MScAgric)--Stellenbosch University, 2013. / ENGLISH ABSTRACT: The optimal farm size and organizational form of agriculture is a widely discussed topic with
little consensus as to which organizational form would be optimal under certain
circumstances. There is often confusion as to what constitutes a corporate farm as well as a
family farm, with the size of the farm often used as a distinguishing factor. This should
however not be the case as there are many extremely large farms that are owner-operated
within South Africa. The distinguishing factor should rather revolve around the management
structures of these farms. It is these management structures that would seem to limit the
metamorphosis of owner-operated farms into large corporate structures.
This thesis uses an analysis of both technical and allocative efficiency in determining the
organizational form chosen within agriculture. It is shown in the thesis that farm size
determines or improves the technical efficiency and this is brought about by the farms ability
to stay abreast with the technological times by having “economies of size” to their advantage.
The evolution of farm size would therefore seem to be driven by this need to obtain
“economies of size” so as to be able to earn comparable wages to off-farm activities. The
attainment of this technical efficiency however does not seem to be linked to the
organizational structure of the farm; it is rather dependant of the size of the farm.
While the size of the farm is an important factor in achieving technical efficiency it is not as
important in determining allocative efficiency, with various studies arguing that larger farms
are less allocatively efficient than smaller farms. This reduced allocative efficiency seems to
stem from various transaction costs and principle agent issues within the corporate setting
that are not prevalent in the owner-operated farms. This is because in the owner-operated
settings the family are the residual claimants to profit, which suggests that they do not have
the incentive to shirk. The opposite is true for the corporate setting where the model is
fraught with moral hazard and other issues of the principle-agent nature, which would seem
to raise the transaction costs of this organizational form, and this has negative implications
for the allocative efficiency with which these farms operate at.
This thesis therefore uses data obtained from such a corporate farm, where the owners of the
farms are kept on as farm managers and the company makes all the production decisions.
This thesis argues that it is these agency issues and transaction costs that hamper this
organizational form while it is shown that the technical efficiency for these farms are high
suggesting that economies of size are important in determining the technical efficiency of
these farms. / AFRIKAANSE OPSOMMING: Die optimale plaasgrootte en organisasievorm in die landbou is ’n onderwerp wat al baie
aandag in die literatuur ontvang het, maar waar daar min ooreenstemming is oor watter
organisasievorm optimaal sal wees onder spesifieke omstandighede. Met die grootte van die
plaas wat dikwels as 'n onderskeidende faktor gebruik word, is daar dikwels verwarring oor
wat ‘n korporatiewe plaas sowel as ʼn familie plaas uitmaak. Dit hoort egter nie die geval te
wees nie, want daar is baie groot plase wat as alleen-eienaar bedryf word in Suid-Afrika
(m.a.w. familie-plase met gehuurde arbeid). Die onderskeidende faktor moet eerder die
bestuur strukture van hierdie plase wees. Dit is hierdie bestuur strukture wat die metamorfose
vanaf eienaar-bedryfde plase na (groot) korporatiewe strukture beperk.
In hierdie tesis word 'n ontleding van beide tegniese en allokatiewe doeltreffendheid gebruik
in die ontleding van die optimale organisasievorm in die landbou. Die tesis bewys dat die
plaas se grootte die tegniese doeltreffendheid bepaal of verhoog, vanweë die groter plase se
beter vermoë om op hoogte te bly met tegnologiese ontwikkeling deur die "ekonomieë van
grootte" tot hul voordeel te gebruik. Plaasgroottes pas aan by die geleentheidskoste van die
eienaar-bestuurder en tegniese doeltreffendheid is nie afhanklik van die organisasiestruktuur
van die plaas nie, maar is eerder afhanklik van die grootte van die plaas.
Terwyl die grootte van die plaas 'n belangrike faktor in die bereiking van tegniese
doeltreffendheid is, is dit nie so belangrik in die bepaling van allokatiewe doeltreffendheid
nie. Verskeie studies wys daarop dat groter plase minder allokatief doeltreffend is as kleiner
plase, hoofsaaklik as gevolg van verskeie transaksiekoste voordele van klein plase. Maar daar
is ook prinsipaal-agent kwessies in die korporatiewe omgewing wat nie algemeen by eienaarbedryfde
plase voorkom nie. Dit is omdat in die geval van die eienaar-bedryfde instellings die
familie aanspraak het op die residuele wins, en dus ʼn aansporing het om opdragte uit te voer.
By korporatiewe plase is daar egter prinsipaal-agent probleme wat gepaard gaan met morele
risiko (‘moral hazard’). Dus het familieplase ʼn koste voordeel oor korporatiewe plase.
Hierdie tesis gebruik dan data wat verkry is uit 'n korporatiewe boerdery onderneming, waar
die eienaars van die plase die plaasbestuurders is en die maatskappy al die produksie besluite
maak. Die tesis wys dat dit hierdie agentskap kwessies en transaksie koste is wat die
organisasievorme belemmer terwyl dit blyk dat die tegniese doeltreffendheid vir dié plase
hoog is wat daarop dui dat die ekonomie van grootte belangrik is in die bepaling van die
tegniese doeltreffendheid van hierdie plase.
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A number of case studies based on Glen Anil Development Corporation Limited, from the listing of the company in 1968 to date of liquidation, 22 February 1977Potgieter, Johan Gerhardus 12 1900 (has links)
Thesis (MBA)--Stellenbosch University, 1987. / ENGLISH ABSTRACT: No abstract available / AFRIKAANSE OPSOMMING: Geen opsomming beskikbaar
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Belastingoorwegings om in gedagte te hou by samesmeltings en oornames van Suid-Afrikaanse maatskappyeDe Bruin, Magdalena Maria 12 1900 (has links)
Thesis (MComm)--Stellenbosch University, 2000. / ENGLISH ABSTRACT: TAX CONSIDERATIONS OF MERGERS AND ACQUISITIONS
During the past few years the South African business environment experienced a
considerable increase in corporate mergers and acquisitions. At a corporate tax
rate of thirty per cent, the tax implications of mergers and acquisitions have an
important impact on the financial success thereof.
By way of background information, a short exposition of the characteristics, the
various forms and the reasons for the increase, of mergers and acquisitions is
provided.
Essentially a merger or acquisition entails the acquisition of either the business
of, or the shares in, the target company. A comparison is drawn between the tax
consequences of the above two options for both parties to mergers and
acquisitions.
The composition of the purchase price payable by an acquiring company in
respect of the acquisition of the target company's business or shares may have
far reaching tax consequences. Consequently, the most commonly used
arrangements relating to payment of the purchase price are scrutinized from a
tax point of view.
The bulk of the study consists of an analysis of particular aspects of mergers and
acquisitions, which may, depending on how a particular transaction is structured,
result in important tax benefits. The analysis is directed towards, firstly,
establishing the tax consequences arising from mergers and acquisitions and,
secondly, suggesting tax efficient structuring methods or alerting against
structuring options that may have detrimental tax results.
Some of the proposed tax structuring techniques have tax efficient results for one
party to the merger or acquisition, but result in corresponding negative tax effects
for the other. There are, however, opportunities to structure a tax efficient
transaction in such a way to ensure that both parties share in the tax benefit. lt is
even possible to, in respect of certain aspects of mergers and acquisitions,
achieve a tax efficient result for both parties to the transaction without any
commensurate disadvantage, or without them having to share the benefits
thereof.
lt is important to evaluate tax planning strategies against the general antiavoidance
measures contained in the doctrine of substance over form and in tax
legislation. Consequently, in the final analysis, the applicability of the antiavoidance
measures to the tax planning strategies proposed in this study, is
considered. / AFRIKAANSE OPSOMMING: BELASTINGOORWEGINGS OM IN GEDAGTE TE HOU BY
SAMESMEL TINGS EN OORNAMES VAN SUID-AFRIKAANSE
MAATSKAPPYE
Korporatiewe samesmeltings en oornames is 'n dinamiese en immer groeiende
area van die Suid-Afrikaanse besigheidsomgewing. Teen 'n korporatiewe
belastingkoers van dertig persent is die belastinggevolge van 'n samesmelting of
oorname 'n belangrike faktor in die finansiele sukses daarvan.
Ter agtergrondinligting word daar in hierdie studie 'n kort uiteensetting van wat 'n
samesmelting en oorname behels, die verskillende vorme wat dit kan aanneem
en die redes waarom samesmeltings en oornames plaasvind, gegee.
In wese kan 'n samesmelting of oorname geskied deur die verkryging van of die
besigheid of die aandele van 'n teikenmaatskappy. 'n Vergelyking tussen die
belastingimplikasies van genoemde twee opsies word uit die perspektief van
beide die verkrygende maatskappy en die teikenmaatskappy, getref.
Die samestelling van die koopprys wat ingevolge 'n oorname of 'n samesmelting
betaalbaar is, kan verreikende belastingimplikasies inhou. Die mees algemene
wyses van betaling, en die belastinggevolge wat daaruit voortvloei, word dus
geanaliseer.
Die studie behels hoofsaaklik 'n ontleding van spesifieke aspekte inherent aan
samesmeltings en oornames wat, afhangend van die strukturering van die
transaksie, verskillende belastinggevolge inhou. Die doel met die ontleding is
tweeledig, naamlik om, eerstens, die belastinggevolge van samesmeltings en
oornames vas te stel en om, tweedens, enersyds voorstelle te maak vir
effektiewe belastingstrukturering, en andersins te waarsku teen
struktureringsopsies wat negatiewe belastinggevolge mag inhou.
Sommige struktureringstegnieke hou voordelige belastinggevolge vir een party
tot 'n samesmelting of oorname in, maar lei tot korresponderende nadelige
belastinggevolge vir die ander party. In sommige gevalle is dit egter moontlik om
'n middeweg tussen die voordeel en korresponderende nadeel te vind, sodat die
partye in die voordeel kan deel. Daar word ook aangetoon dat sommige aspekte
van samesmeltings en oornames, indien dit noukeurig beplan word,
belastingvoordele sonder enige korresponderende nadele vir beide partye kan
inhou.
Belastingbeplanningstegnieke moet egter aan die algemene
teenvermydingsmaatreels wat in die leerstuk van wese bo vorm, asook in
belastingwetgewing, vervat word, gemeet word. Die studie word dus afgesluit
met 'n bespreking van die toepaslikheid van die algemene
teenvermydingsmaatreels op die voorstelle wat gemaak word ten opsigte van
belastingstruktureringsopsies.
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The tax treatment of debt and equity in leverage finance transactionsTettey, Joseph Rydell January 2016 (has links)
Presented to the School of Accountancy
University of the Witwatersrand, Johannesburg
This research report is submitted to the faculty of Commerce, Law and Management in partial fulfilment of the requirements for the Degree of
Master of Commerce (specialising in Taxation)
Date: 31 March 2016 / This research focuses on large corporate transactions and acknowledges that they play a significant role in the allocation of resources in society. For this reason (1) the composition of firms’ capital structure and (2) how they choose to fund their investments are important.
The South African income tax system has a bias towards debt and this bias (1) distorts the financing and investment decisions of firms; and (2) creates international tax arbitrage opportunities. These circumstances are not exclusive to South Africa. In order to address these distortions and loopholes the National Treasury and the SARS Commissioner have introduced complicated interest deduction limitations.
This research critically analyses (1) the new adjusted tax rules concerning interest deduction limitations in finance transactions and (2) whether these new rules encourage investment. To assist with this critical analysis we use corporate finance theory to examine debt push-down transactions/structures because these structures are seen as highly tax-efficient for investors (both foreign and local).
This research demonstrates that there are many different ways to finance a transaction but ultimately the choice of finance lies along the continuum between the issue of debt or equity. From an economic perspective this research confirms that there is no material reason for the disparate treatment between debt and equity. However from a legal perspective debt and equity instruments are materially distinct and thus tax considerations are influential in selecting the form of finance used in a transaction.
This research not only concludes that leverage transactions utilising excessive debt pose a risk to tax revenues, tax sovereignty and tax fairness but also that the artificial statutory treatment of interest deductions on leverage transactions and working capital facilities means that (1) firms’ ability to finance their operations is reduced, (2) the value of firms is reduced and (3) the incentive for investors to invest in South Africa is also reduced. / MT2017
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