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This work entails a study of some of the schemes that are employed by country residents when companies and trusts are used as vehicles for investing in offshore tax-haven and low tax jurisdictions so as to avoid taxes. The study also entails a critical analysis of the effectiveness of the some of the laws in South Africa that curb such offshore tax avoidance schemes. Similar laws in the United Kingdom and in the United States are analysed in order to come up with some recommendations that could be considered for possible reform of the relevant South African laws where they are found wanting. Since offshore tax avoidance is an international issue, the effectiveness of the recommendations of some international organisations in preventing the depletion of countries' tax bases are also analysed. / JURISPRUDENCE / LLD

This work entails a study of some of the schemes that are employed by country residents when companies and trusts are used as vehicles for investing in offshore tax-haven and low tax jurisdictions so as to avoid taxes. The study also entails a critical analysis of the effectiveness of the some of the laws in South Africa that curb such offshore tax avoidance schemes. Similar laws in the United Kingdom and in the United States are analysed in order to come up with some recommendations that could be considered for possible reform of the relevant South African laws where they are found wanting. Since offshore tax avoidance is an international issue, the effectiveness of the recommendations of some international organisations in preventing the depletion of countries' tax bases are also analysed. / JURISPRUDENCE / LLD

BACKGROUND: Harmful drinking among students in tertiary institutions has become a major public health issue worldwide. Botswana is among the countries that are experiencing this problem. Abuse of alcohol amongst students is linked to road crushes, intentional and unintentional injuries, raping and an array of communicable diseases notably HIV/AIDS. Drinking among students could be a function of personal and environmental factors. PURPOSE: The purpose of the study was to identify factors that are consistent with abuse of alcohol among students in tertiary institutions in Gaborone. METHOD: This is a quantitative, non-experimental, cross sectional descriptive study. Data were collected from a sample of students in tertiary institutions. SPSS was used for the analysis of data. RESULTS: The study has revealed hazardous drinking among students. The use of alcohol was predicted on demographic, psychological and environmental factors of respondents. Influence from a close friend, year level of study and area of residence were correlates of drinking among students. Institution based educational interventions that focus on building leadership skills of students are critical in addressing issues of alcohol in tertiary institutions. Statutory measures are necessary to limit students’ access to alcohol. CONCLUSION: The study has identified factors that are related to abuse of alcohol among students. The findings could be used to strengthen evidence based planning and implementation of interventions for tackling issues of alcohol in tertiary institutions. There is a need for future research on this area using qualitative approach. / Health Studies / M.A. (Public Health)

BACKGROUND: Harmful drinking among students in tertiary institutions has become a major public health issue worldwide. Botswana is among the countries that are experiencing this problem. Abuse of alcohol amongst students is linked to road crushes, intentional and unintentional injuries, raping and an array of communicable diseases notably HIV/AIDS. Drinking among students could be a function of personal and environmental factors. PURPOSE: The purpose of the study was to identify factors that are consistent with abuse of alcohol among students in tertiary institutions in Gaborone. METHOD: This is a quantitative, non-experimental, cross sectional descriptive study. Data were collected from a sample of students in tertiary institutions. SPSS was used for the analysis of data. RESULTS: The study has revealed hazardous drinking among students. The use of alcohol was predicted on demographic, psychological and environmental factors of respondents. Influence from a close friend, year level of study and area of residence were correlates of drinking among students. Institution based educational interventions that focus on building leadership skills of students are critical in addressing issues of alcohol in tertiary institutions. Statutory measures are necessary to limit students’ access to alcohol. CONCLUSION: The study has identified factors that are related to abuse of alcohol among students. The findings could be used to strengthen evidence based planning and implementation of interventions for tackling issues of alcohol in tertiary institutions. There is a need for future research on this area using qualitative approach. / Health Studies / M.A. (Public Health)

La société holding est une réalité économique dont l’importance ne cesse d’augmenter. Plusieurs États offrent des régimes de faveurs fiscales pour attirer les holdings sur leurs territoires. Le système fiscal turc n’offre pas un tel «régime holding» mais il comporte plusieurs dispositions qui offrent certains avantages aux participations turques et étrangères. Une fiscalité avantageuse pour les holdings est intéressante pour un État dans la mesure où elle lui permet d’attirer les entreprises. Les dispositions fiscales peuvent rendre un territoire attractif et compétitif mais elles peuvent inciter une évasion fiscale à l’intérieur même du territoire. Le second risque engendré par le régime fiscal avantageux est l’établissement d’une concurrence fiscale déloyale. Les éléments clés d’une fiscalité idéale pour la société holding prennent en compte, d’une part la distribution des bénéfices de la holding, et d’autre part, les bénéfices provenant de ses propres participations, notamment les dividendes provenant de ses filiales et les plus-values de cession de ces participations. Par ailleurs, le régime fiscal holding doit être attractif et compétitif tout en restant compatible avec les principes reconnus du droit fiscal international. / The holding company is an economic reality whose importance is still increasing. Several countries offer tax benefits plans to attract holdings in their territories. The Turkish tax system does not offer such a "holding plan" but it contains several provisions that provide certain benefits to Turkish and foreign investments. Tax advantages for holding companies are important for the State to the extent that it attracts businesses and group companies. The tax provisions can make an attractive and competitive territory, yet they may increase tax evasion within the same territory. Another risk caused by the advantageous tax regime is harmful tax competition. The key elements of an ideal tax system of holding companies are about, first of all, the distribution of profits of the holding company and secondly, income from its own shares, including dividends from its subsidiaries and the capital gains disposal of their shares. Furthermore, the holding company tax system must be both competitive and attractive and at the same time it must be compatible with the principles acknowledged by international tax law.

Indiana University-Purdue University Indianapolis (IUPUI) / Descriptions about the matting of hair given by medical practitioners show a significant commonality indicating it as a historic health problem prevalent across the globe, however with less clarity about its etiopathogenesis. In southwestern India, the emergence of matting of hair is considered a deific phenomenon; consequently, people worship the emerged matted hair and restrict its removal. Superstitious beliefs impose a ritualistic lifestyle on affected women depriving them of health and well-being, further leading to stigma, social isolation, and marginalization. For unmarried females, the matting of hair can result in dedication to the coercive devadasi custom whereby women end up marrying a god or goddess. To date, the state, academia, and disciplines such as medicine and psychology have paid far too little attention to the social, cultural, and health concerns of the women affected by matted hair. A Heideggerian interpretive phenomenological study was conducted to document the lived experience of women affected by the phenomenon of matting of hair. The subjective accounts of 13 jata-affected women selected through purposive sampling were documented to understand their health and human rights marginalization through harmful cultural practices surrounding matting of hair. Seven distinct thematic areas emerged from the study exemplified their lived experience as jata-affected women. The prevalent gender-based inequity revealed substantial vulnerability of women to health and human rights marginalization through harmful cultural practices. The ontological structure of the lived experience of matting of hair highlighted the unreflective internalization of religious-based discourse of matting of hair. The hermeneutic exploration revealed events that exemplified jata-affected women’s compromised religiosity, and control of their well-being, human development, and ontological security. The religious-based interpretation of matting of hair and associated practices marginalize the health and human rights of affected women through family members, institutions, society, and religious-based systems. The study demonstrates the need for collaborative, evidence-based interventions and for effective domestic as well as global policies to prevent the health and human rights violations of women through cultural practices. The study offered foundational evidential documentation of the phenomenon of matting of hair as a harmful cultural practice that compromises women’s right to health and well-being.

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