Showing 1 - 12 results of 12 for search '"OECD"', query time: 0.26s Refine Results
  1. 1
    Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector
    by Joseph, Arlene
    Published 2018
    “...This dissertation focuses on the Organisation for Economic Co-operation and Development ('OECD...”
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    Dissertation
  2. 2
    The relevance of the OECD BEPS action plan 2 recommnedations for selected aspects of cross border arbitrage through selected hybrid instruments and entity arrangements in South African Income Tax Law
    by McCann, Patrick Joseph
    Published 2016
    “...Includes bibliographical references === The OECD made certain recommendations in its 2014...”
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    Dissertation
  3. 3
    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
    by Lovely, Graham
    Published 2015
    “... provisions of Article 24(5) of the OECD MTC. This question has not been decided in a South African court...”
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    Dissertation
  4. 4
    Searching for common deviations from South Africaﾒs Tax Treaty Policy: The relationship with North Africa, West Asia and Eastern Europe
    by Gordhan, Komil Dilap
    Published 2020
    “... for Economic Co-operation and Development (“OECD”) Model was prepared by developed countries of the world...”
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    Dissertation
  5. 5
    Seeking deviations from South Africaﾒs tax treaty policy with respect to treaties in Africa: evidence from the treaty practice
    by de Wet, Mary-Ann
    Published 2020
    “.... This analysis is used to identify any significant deviations in these treaties as compared to the OECD Model...”
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    Dissertation
  6. 6
    The Taxation of International (non-resident) Sportspersons in South Africa
    by West, Craig
    Published 2014
    “...This thesis tests, firstly, the relevance of the OECD Model article 17 (the sportsperson article...”
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    Doctoral Thesis
  7. 7
    Seeking arm’s length: An evaluation of formulary apportionment and predetermined margins as alternative or supplementary methods to establish proxy arm’s length transfer prices for multinational intercompany transactions in South Africa
    by Raymond, Bonita
    Published 2020
    “... of the state (OECD:G20 Working group, 2014); (Economic Commissions for Africa, 2018). Section 31 of the South...”
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    Dissertation
  8. 8
    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
    by Bland, Timothy Luke
    Published 2014
    “... of the OECD Model, as it recognised that the OECD Model is one of the most widely used Models for negotiating...”
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    Dissertation
  9. 9
    Does the Permanent Establishment article give Namibia adequate taxing rights?An analysis of tax convention models in the mining and fishing industries
    by Swartz, Rikotoka Punaje
    Published 2019
    “... being the Organisation for Economic Cooperation and Development (“OECD”) and United Nations (“UN...”
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    Dissertation
  10. 10
    Seeking common deviations from South Africa’s tax treaty policy: a comparative analysis identifying trends (regional or otherwise) in treaty practice in bi-lateral tax treaties with countries in Asia, Australasia, North America and South America
    by Decloedt, Andre
    Published 2020
    “... that the OECD Model and its positions recorded in the commentaries are now widely accepted as the national tax...”
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    Dissertation
  11. 11
    An analysis of treaties for the exchange of information for tax purposes impacting a South African retail sector taxpayer and financial institutions trading in the Southern African development community region
    by Van Schalkwyk, Johannes Murray
    Published 2015
    “... Convention (MTC) of the Organisation for Economic Cooperation and Development (OECD). Treaties included...”
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    Dissertation
  12. 12
    Characterisation for treaty purposes of manufactured dividends received in terms of securities lending arrangements
    by Vanlierde, Angela
    Published 2021
    “... was done through an analysis of the ‘dividends' definition in Article 10 of the 2017 OECD model convention...”
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    Dissertation
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