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Review of the definition of permanent establishment

OECD - February 21 2019 Typically, a tax treaty defines a PE using the following two general tests…

Review of venture capital company regime

South Africa - February 21 2019 Various legislative amendments to s12J have given rise to an increased participation in the asset class, evidenced by the increasing number of…

Special Edition Budget Speech Alert 2019

South Africa - February 20 2019 National Treasury amended legislation governing share buy-backs and dividend stripping in 2017 and again in 2018. The specific anti-avoidance…

Ben Strauss, Dries Hoek, Emil Brincker, Gerhard Badenhorst, Heinrich Louw, Jerome Brink, Jessica Carr, Louis Botha, Mareli Treurnicht, Mark Linington, Petr Erasmus, Varusha Moodaley.

A diver’s quandary: The role of domestic law in interpreting double taxation agreements

OECD, South Africa, United Kingdom - February 15 2019 In the international tax law arena, agreements for the Avoidance of Double Taxation (DTAs) are, very simply, concluded between states with a view to…

Tsangadzaome Mukumba.

What is meant by 'fit and proper'? The Australian Federal Court sheds some light

Australia - November 30 2018 The concept of a ‘fit and proper’ person is a fundamental one in many professions, jurisdictions and organisations as it is used to determine a…