Browsing by Subject "Thin capitalisation"
Now showing items 1-4 of 4
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An analysis of Section 23M in light of the OECD best practice approach to interest limitation
(North-West University (South Africa) , Potchefstroom Campus, 2016)The ability of multinational companies to reduce their tax burden on their worldwide profits has generated public interest in recent years. Excessive interest deductions can be used to shift profits from one country to ... -
An analysis of Section 23M in light of the OECD guidelines relating to thin capitalisation
(2015)Base erosion in the form of profit shifting has become an increasing concern internationally as well as in South Africa. A significant type of base erosion in South Africa is in the form of excessive interest deductions ... -
An evaluation of transfer pricing provisions for financial assistance granted by a foreigner to a resident
(North-West University (South Africa), 2020)Transfer pricing rules are anti-avoidance measures that are governed by section 31 of the South African Income Tax Act No. 58 of 1962 (Income Tax Act). Section 31(6) of the Income Tax Act provides an exemption (subject to ... -
Thin capitalisation : an analysis of the application of the amended section 31(3) of the Income Tax Act no. 58 of 1962
(North-West University (South Africa), Vaal Triangle Campus, 2015)The current Income Tax legislation, in relation to thin capitalisation, requires South African-based entities to transact at an arm’s length basis. This is in accordance with the Draft Interpretation Note issued by the ...