A critical review of the source and residence principles of taxation of income : a place for both principles in the South African tax system?

• Main Author: Hiepner, Albert James
• Other Authors: Swart, G. J.
• Format: Others
• Language: en
• Published: 2015
• Subjects: Source based tax system; The source and residence principles; The case for a hybrid system in South Africa based on both the source and residence principles; Real or dominant source; The apportionment of income between sources; The taxation of passive (investment) income on a worldwide basis (the residence prindple); The taxation of active (business) income on the basis of source; The Act and/or the 1997 Act (Income Tax Act of 1962 and/or Income Tax Act of 1997); Section 9 deeming provisions; International income; Permanent establishment; Interest; Royalties; 343.52068; Income tax > Law and legislation > South Africa
• Online Access: Hiepner, Albert James (1997) A critical review of the source and residence principles of taxation of income : a place for both principles in the South African tax system?, University of South Africa, Pretoria, <http://hdl.handle.net/10500/16948>; http://hdl.handle.net/10500/16948

In support of a short dissertation entitled - "A critical review of the source and residence principles of taxation of income : A place for both principles in the South African tax system?" Qbjeetives To review and critically examine the application of the source and reside.nce principles regarding the taxption of income in South Africa, and to reveal the extent of the existence and application of a hybrid tax system in respect of the source and residence principles. To examine the legal principles and policy considerations arising from the existence of a hybrid tax system, inter alia, in the context of the Fifth Interim Report of the Katz Commission and consequent legislative developments. with a view to recommending. where appropriate, tax reform. Methodology iDd AQProach A review of relevant authority,liter@ture, principles and legislation. Conclusion To draw conclusions and recommendations regarding the merits of adopting a hybrid system in South Africa and, where appropriate, recommend legislative reforms particularly with regard to business income. === Mercantile Law === LL.M. (Mercantile Law)