An analysis of the possible fiscal consequences of a controlled foreign company being declared resident in South Africa– may SARS have its cake and eat it?
The issue considered in this paper proceeds from the basis of a hypothetical income tax assessment issued by SARS against a hypothetical taxpayer. The circumstances under which the hypothetical assessment is raised are as follows: suppose that Company A, a South African resident, owns 100% of the pa...
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| Format: | Dissertation |
| Language: | English |
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Faculty of Law
2020
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| Online Access: | http://hdl.handle.net/11427/32270 |