1,720,963 research outputs found
The Tax base of South African individuals : an international comparison
Get PDFDissertation (MCom)--University of Pretoria, 2013.South Africa changed its tax system from a source-based to a resident-based
system in 2001. This change is in line with tax reforms worldwide. However,
over the last two decades, personal income tax reforms have not resulted in a
noticeable increase in tax revenue worldwide, even though governments find
themselves hard-pressed to maintain or increase their expenditure.
The aim of this study was to compare the South African tax base, which relies
on taxing individuals, with the tax base used in another developing country,
namely India, as well as to those applied in two developed countries, namely
the United Kingdom (UK) and the United States (US). This comparison
identified similarities and differences between the countries, and highlighted
possible improvements to South African tax legislation in order to broaden the
country‟s tax base and potentially increase tax revenues. For the purposes of
the study, a tax base can be defined as the total income of an individual, after
allowing for specified deductions, allowances and other adjustments, on which
tax is levied.
It was determined that the tax base used in South Africa is similar in some
respects to those used in India, the UK and the US. An improvement that South
Africa could adopt is the inclusion of the annual value of house property, as
specified in the Indian tax system. The employment abroad exclusion from
income could be replaced by a foreign-earned income exclusion, as applied in
the US tax system. It was also determined that permitting certain deductions
could in fact increase the tax base, as these deductions could entice taxpayers
to register for tax, therefore increasing tax compliance and ultimately increasing
tax revenue. By adopting any of the advantages of the other tax systems, South
Africa can broaden its tax base and generate additional tax revenue to support
the government‟s needs.gm2014Taxationunrestricte
Voluntary employee reporting by the wholesale and retail companies listed on the Johannesburg Stock Exchange
Get PDFDissertation (MCom)--University of Pretoria, 2011.No abstract available. CopyrightAccountingunrestricte
The value relevance of mandatory IFRS adoption in South Africa
Get PDFDissertation (MCom)--University of Pretoria, 2011.No abstract available. CopyrightAccountingunrestricte
Promoting South Africa as an investment gateway : the influence of tax legislation
Get PDFDissertation (MCom)--University of Pretoria, 2013.The South African government announced in 2008 that it intends to promote South Africa as a suitable company headquarter jurisdiction for investment in Africa in general and the sub-Sahara region in particular. The 2010 Taxation Laws Amendment Bill introduced a number of tax changes to lure headquarter companies to South Africa. The new South African headquarter company regime attempts to attract foreign direct investment through these changes. The government plans to make South Africa a gateway for African investments. In order to achieve this goal the regulatory, economic and legal frameworks need to be suitable for international investment. This study analyses the tax characteristics of an ideal holding company regime and investigate the importance that is placed on tax considerations compared to non-tax considerations by companies when faced with investment decision making and whether tax is a primary driver of such decisions.
A single source ethnographic case study is used to analyse the process followed by an organisation, and the considerations used by the key decision makers within this organisation, for setting up a holding company in South Africa to drive an investment and business expansion.
The case study consists of an investigation into the process followed, the strategy formulated and the structuring of the business for making the investment in selected African countries. It further investigates where the ultimate holding company will be located as a headquarter company for all further Africa business expansion.
It was found that the tax considerations are mainly a favourable capital gains tax regime, low income taxes, no or low tax on dividends, a favourable tax treaty network, the absence of controlled foreign company legislation and a liberal thin capitalisation and transfer pricing regime. Non-tax factors also play a significant role in decision making when considering the investment destination. These factors include: economic and political stability; adequate physical, business, accounting and legal infrastructure; the absence (or limited presence) of bureaucratic obstacles; adequate communication channels; the ability to repatriate profits freely; an effective banking system; and the availability of an adequate dispute resolution mechanism.
There is a definite distinction between tax specific strategies where enterprises are set up to take advantage of tax incentives provided by certain jurisdictions and where an investment decision is taken and aligned with business decisions to align these strategies to take advantage of a favourable tax regime
Jurisdictions that only concentrate on tax incentives will find it difficult to attract foreign direct investment. Decision makers that are held responsible for investors’ capital will take tax as well as non-tax aspects into account when deciding to invest in a country and to set up holding company in that jurisdictions. It is therefore important for a jurisdiction to provide an environment that is conducive to do business in order to attract foreign direct investment.lmchunu2014Taxationunrestricte
Determining the impact of the 2014 OECD update to beneficial ownership in equity derivatives and financial instruments transactions
Get PDFDissertation (MCom)--University of Pretoria, 2016.Beneficial ownership can be distinguished from legal ownership and is the cornerstone for the granting of treaty benefits under the income articles of the Organisation of Economic Cooperation and Development (OECD) Model Tax Convention (MTC). Until recently, beneficial ownership was determined with reference to the domestic laws of states contracting bilateral tax treaties. Foreign case law provided further information on the meaning of the term.
In updating the Commentary to the 2014 MTC, the OECD defined beneficial ownership as having the right to use and enjoy the income unconstrained by any contractual or legal obligation to distribute that income further to another party. In the financial industry, where banks and brokers routinely trade or hedge risk, financial instruments written over equities typically shift economic risks and rewards to contracting parties. As a consequence, the holder of the equity shares is divested from all or selected rights, obligations, risks and rewards that are ordinarily associated with ownership. The question then arises whether the holder of the equity share is the beneficial owner of that share or of the dividend that it produces.
This study aims to determine beneficial ownership of equities and dividends where risk offsets have been concluded. It comprises a doctrinal research study that formulates the rule of law in respect of beneficial ownership and then applies it to a selection of transactions involving equity derivatives and financial instruments.tm2016TaxationMComUnrestricte
Going Beyond Counting First Authors in Author Co-citation Analysis
Get PDFThe present study examines one of the fundamental aspects of author co-citation analysis (ACA) - the way co-citation
counts are defined. Co-citation counting provides the data on which all subsequent statistical analyses and mappings
are based, and we compare ACA results based on two different types of co-citation counting - the traditional type that
only counts the first one among a cited work's authors on the one hand and a non-traditional type that takes into
account the first 5 authors of a cited work on the other hand. Results indicate that the picture produced through this non-traditional author co-citation counting contains more coherent author groups and is therefore considerably clearer. However, this picture represents fewer specialties in the research field being studied than that produced through the traditional first-author co-citation counting when the same number of top-ranked authors is selected and analyzed. Reasons for these effects are discussed
Variations on the Author
Get PDF“Variations on the Author” discusses two of Eduardo Coutinho’s recent films (Um Dia na Vida, from 2010, and Últimas Conversas, posthumously released in 2015) and their contribution to the general question of documentary authorship. The director’s filmography is characterized by a consistent yet self-effacing form of authorial self-inscription: Coutinho often features as an interviewer that rather than express opinions propels discourses; an interviewer that is good at listening. This mode of self-inscription characterizes him as an author who is not expressive but who is nonetheless markedly present on the screen. In Um Dia na Vida, however, Coutinho is completely absent form the image, while Últimas Conversas, on the contrary, includes a confessional prologue that moves the director from the margins to the center of his films. This article examines the ways in which these works stand out in the filmography of a director who offers new insights into the notion of cinematic authorship
Appropriate Similarity Measures for Author Cocitation Analysis
Get PDFWe provide a number of new insights into the methodological discussion about author cocitation analysis. We first argue that the use of the Pearson correlation for measuring the similarity between authors’ cocitation profiles is not very satisfactory. We then discuss what kind of similarity measures may be used as an alternative to the Pearson correlation. We consider three similarity measures in particular. One is the well-known cosine. The other two similarity measures have not been used before in the bibliometric literature. Finally, we show by means of an example that our findings have a high practical relevance.information science;Pearson correlation;cosine;similarity measure;author cocitation analysis
Dispelling the Myths Behind First-author Citation Counts
Get PDFWe conducted a full-scale evaluative citation analysis study of scholars in the XML research field to explore just how different from each other author rankings resulting from different citation counting methods actually are, and to demonstrate the capability of emerging data and tools on the Web in supporting more realistic citation counting methods. Our results contest some common arguments for the continued
use of first-author citation counts in the evaluation of scholars, such as high correlations between author rankings by first-author citation counts and other citation
counting methods, and high costs of using more realistic citation counting methods that are not well-supported by the ISI databases. It is argued that increasingly available digital full text research papers make it possible for citation analysis studies to go beyond what the ISI databases have directly supported and to employ more
sophisticated methods
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