Does the proposed dividends tax overcome the international tax flaws that secondary tax on companies may have, namely exclusion from the scope of some double tax agreements and violation of the anti-discrimination provisions embodied in the OECD mode

Description

Includes bibliographical references (leaves 54-55). / Secondary tax on companies (STC) and the new dividends tax and its exemptions therefrom could be in contravention of the non-discrimination provisions of Article 24(5) of the OECD MTC. This question has not been decided in a South African court. This dissertation proposes the resolution to this question. The outcome of this research may be particularly relevant in the context of the proposed new dividends tax and value extraction tax (“VET”) and the exemptions therefrom, which are, again, based on residency.

Links & Downloads

1. http://hdl.handle.net/11427/11135

Tags

Taxation

Additional Fields

Identifer	oai:union.ndltd.org:netd.ac.za/oai:union.ndltd.org:uct/oai:localhost:11427/11135
Date	January 2011
Creators	Lovely, Graham
Contributors	West, Craig
Publisher	University of Cape Town, Faculty of Law, Department of Commercial Law
Source Sets	South African National ETD Portal
Language	English
Detected Language	English
Type	Master Thesis, Masters, MCom
Format	application/pdf