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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
Includes bibliographical references (leaves 54-55).
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| Other Authors: | |
| Format: | Thesis |
| Language: | English |
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Department of Commercial Law
2015
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| _version_ | 1867613264737730560 |
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| access_status_str | Open Access |
| author | Lovely, Graham |
| author2 | West, Craig |
| author_browse | Lovely, Graham West, Craig |
| author_facet | West, Craig Lovely, Graham |
| author_sort | Lovely, Graham |
| collection | Thesis |
| description | Includes bibliographical references (leaves 54-55). |
| format | Thesis |
| id | oai:open.uct.ac.za:11427/11135 |
| institution | University of Cape Town (South Africa) |
| language | eng |
| last_indexed | 2026-06-10T12:33:23.204Z |
| license_str | Not specified — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UCTD — University of Cape Town Open Access Repository |
| publishDate | 2015 |
| publishDateRange | 2015 |
| publishDateSort | 2015 |
| publisher | Department of Commercial Law |
| publisherStr | Department of Commercial Law |
| record_format | dspace |
| source_str | UCTD — University of Cape Town Open Access Repository |
| spelling | oai:open.uct.ac.za:11427/11135 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 Lovely, Graham West, Craig Taxation 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. 2015-01-03T05:42:38Z 2015-01-03T05:42:38Z 2011 Master Thesis Masters MCom http://hdl.handle.net/11427/11135 eng application/pdf Department of Commercial Law Faculty of Law University of Cape Town |
| spellingShingle | Taxation Lovely, Graham 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 |
| thesis_degree_str | Master's |
| title | 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 |
| title_full | 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 |
| title_fullStr | 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 |
| title_full_unstemmed | 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 |
| title_short | 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 |
| title_sort | 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 |
| topic | Taxation |
| url | http://hdl.handle.net/11427/11135 |
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