Essays about: "Tradehold Ltd"

Found 1 essay containing the words Tradehold Ltd.

  1. 1. Potential double tax treaty override of South African exit taxation law – how do tax treaties allocate the right to tax unrealized gains?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Thina Bambeni; [2015]
    Keywords : South Africa; South African exit tax; treaty override; Tradehold Ltd; Shuttleworth v South African Reserve Bank; Law and Political Science;

    Abstract : South African income tax legislation makes provision for the levying of exit taxes or charges when individuals emigrate from or companies cease to be residents or become headquarter companies, or when controlled foreign companies (CFC) cease to be CFCs otherwise than by way of becoming residents. As indicated by the title the discourse followed in this paper entails the analysis of treaties to ascertain the connecting factors employed by the OECD Model treaty giving rise to signatories levying exit taxes. READ MORE