| Summary: | 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)
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