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Use of and variance from the United Nations model tax treaty clauses for tax treaties concluded by a group of Southern African Development Community Countries

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Main Author: Bland, Timothy Luke
Other Authors: West, Craig
Format: Thesis
Language:English
Published: Department of Finance and Tax 2014
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access_status_str Open Access
author Bland, Timothy Luke
author2 West, Craig
author_browse Bland, Timothy Luke
West, Craig
author_facet West, Craig
Bland, Timothy Luke
author_sort Bland, Timothy Luke
collection Thesis
description Includes abstract.
format Thesis
id oai:open.uct.ac.za:11427/5909
institution University of Cape Town (South Africa)
language eng
last_indexed 2026-06-10T12:31:58.458Z
license_str Not specified — see source repository
provenance_str_mv Harvested via OAI-PMH from UCTD — University of Cape Town Open Access Repository
publishDate 2014
publishDateRange 2014
publishDateSort 2014
publisher Department of Finance and Tax
publisherStr Department of Finance and Tax
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source_str UCTD — University of Cape Town Open Access Repository
spelling oai:open.uct.ac.za:11427/5909 Use of and variance from the United Nations model tax treaty clauses for tax treaties concluded by a group of Southern African Development Community Countries Bland, Timothy Luke West, Craig Taxation Includes abstract. Includes bibliographical references. Africa has been experiencing significant growth over the last few years, with many seeing Africa as the next investment destination. This increased growth in international trade and investment could broaden and deepen the tax base for African countries which could be a source of additional tax revenue. In particular, the SADC comprises a group of African countries which has as one of their common goals the promotion of sustainable and equitable economic growth. One possible way of achieving this goal could be through the use of effective tax treaties, allowing for greater retention of taxing rights over income flows from FDI, which could go a long way in deepening and broadening the tax base for the SADC countries. This could assist the SADC countries in promoting the growth and development of their economies. A greater retention of taxing rights over income by the SADC countries could be achieved through the use of the UN Model. This Model has primarily been designed to assist developing countries in retaining greater taxing rights over income in order to assist with their development and growth.Therefore, this dissertation has primarily focused on the use of and variation from the UN Model treaty clauses by a group of SADC countries in order to determine the extent of the application of the provisions of the UN Model in the SADC countries’ tax treaties. This analysis has specifically considered the distributive rules of the UN Model dealing with the most common forms of income that are likely to arise from FDI, namely: business profits, income from immovable property, dividends, interest, royalties, capital gains, income from employment and pensions. The focus has been on whether the SADC countries have been able to retain greater taxing rights over these forms of income by making use of the provisions of the UN Model. However, at the same time, the analysis also considered the provisions of the OECD Model, as it recognised that the OECD Model is one of the most widely used Models for negotiating tax treaties amongst both developed and developing countries. By considering the provisions of the OECD Model in this dissertation, it has allowed for a useful and meaningful analysis of any variations from the UN Model. 2014-07-31T12:41:41Z 2014-07-31T12:41:41Z 2013 Master Thesis Masters MCom http://hdl.handle.net/11427/5909 eng application/pdf Department of Finance and Tax Faculty of Commerce University of Cape Town
spellingShingle Taxation
Bland, Timothy Luke
Use of and variance from the United Nations model tax treaty clauses for tax treaties concluded by a group of Southern African Development Community Countries
thesis_degree_str Master's
title Use of and variance from the United Nations model tax treaty clauses for tax treaties concluded by a group of Southern African Development Community Countries
title_full Use of and variance from the United Nations model tax treaty clauses for tax treaties concluded by a group of Southern African Development Community Countries
title_fullStr Use of and variance from the United Nations model tax treaty clauses for tax treaties concluded by a group of Southern African Development Community Countries
title_full_unstemmed Use of and variance from the United Nations model tax treaty clauses for tax treaties concluded by a group of Southern African Development Community Countries
title_short Use of and variance from the United Nations model tax treaty clauses for tax treaties concluded by a group of Southern African Development Community Countries
title_sort use of and variance from the united nations model tax treaty clauses for tax treaties concluded by a group of southern african development community countries
topic Taxation
url http://hdl.handle.net/11427/5909
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