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Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources?
Includes bibliographical references (leaves 115-119).
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| Other Authors: | |
| Format: | Thesis |
| Language: | English |
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Department of Commercial Law
2015
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| _version_ | 1867613198958460929 |
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| access_status_str | Open Access |
| author | Strandvik, Ulrik Bernhard |
| author2 | West, Craig |
| author_browse | Strandvik, Ulrik Bernhard West, Craig |
| author_facet | West, Craig Strandvik, Ulrik Bernhard |
| author_sort | Strandvik, Ulrik Bernhard |
| collection | Thesis |
| description | Includes bibliographical references (leaves 115-119). |
| format | Thesis |
| id | oai:open.uct.ac.za:11427/11806 |
| institution | University of Cape Town (South Africa) |
| language | eng |
| last_indexed | 2026-06-10T12:32:20.328Z |
| 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:11427/11806 Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources? Strandvik, Ulrik Bernhard West, Craig Taxation Includes bibliographical references (leaves 115-119). This thesis tests the sufficiency of the definition of permanent establishments (PE), as contained in the Double Tax Agreements (DTAs) of selected "fishing rich" African countries, in protecting their taxing rights over profits made by non-residents from fishing in the waters of their states. The concept and meaning of "fixed place of residence" and "any other place of extraction” of natural resources is analysed in the context of establishing a PE in the Source State, taking various rules of interpretation, commentaries, judicial and academic views into account. It is concluded that although there are strong arguments in support of the view that a fishing vessel can be considered a fixed place of business, a prudent approach should be adopted. A fishing vessel is not a PE, unless specifically included in the specific DTA of Contracting States. 2015-01-08T20:05:51Z 2015-01-08T20:05:51Z 2011 Master Thesis Masters MCom http://hdl.handle.net/11427/11806 eng application/pdf Department of Commercial Law Faculty of Law University of Cape Town |
| spellingShingle | Taxation Strandvik, Ulrik Bernhard Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources? |
| thesis_degree_str | Master's |
| title | Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources? |
| title_full | Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources? |
| title_fullStr | Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources? |
| title_full_unstemmed | Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources? |
| title_short | Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources? |
| title_sort | africa and the taxation of permanent establishments is the definition of permanent establishment as used in the double tax agreements of selected fishing rich african countries sufficient to protect the taxing rights on those diminishing natural resources |
| topic | Taxation |
| url | http://hdl.handle.net/11427/11806 |
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