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). === 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...
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| Format: | Dissertation |
| Language: | English |
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University of Cape Town
2015
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| Online Access: | http://hdl.handle.net/11427/11135 |
| Summary: | 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. |
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