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The commonalities or divergence of the meaning of beneficial owner in a treaty (International) and domestic context by Tasneem Koorowlay.

Includes abstract. / Includes bibliographical references. / The aim of this dissertation is to establish the relevance of the international interpretation of beneficial owner to SA’s interpretation of the concept. The phrase “beneficial owner” was introduced into the South African Income Tax Act in April 2012 following an intention to align South African tax as regards dividends with international norms. The concept is applied in a domestic context by various countries and in numerous bilateral tax treaties and has been a subject of debate across numerous foreign courts.

Identiferoai:union.ndltd.org:netd.ac.za/oai:union.ndltd.org:uct/oai:localhost:11427/5907
Date January 2013
CreatorsKoorowlay, Tasneem
ContributorsWest, Craig
PublisherUniversity of Cape Town, Faculty of Commerce, Department of Finance and Tax
Source SetsSouth African National ETD Portal
LanguageEnglish
Detected LanguageEnglish
TypeMaster Thesis, Masters, MCom
Formatapplication/pdf

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