A comparative analysis of the usage of the concept of “beneficial owner” in South African double tax agreements
M.Com. (SA and International Tax) === The term “beneficial owner” is found in 64 of the 71 double tax agreements signed by South Africa. However, there is no definition of the term in the Income Tax Act or within the orbit of international taxation. There are international court cases in relation to...
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2014
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| Online Access: | http://hdl.handle.net/10210/9685 |