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Title "Place of effective management" - a South Africa perspective
Full text http://upetd.up.ac.za/thesis/available/etd-07252013-120735/
Date 2013
Author(s) Jonker, Janien
Contributor(s) Adv C Louw
Abstract The comments submitted by The South African Institute of Chartered Accountants (hereinafter referred to as SAICA) to the Discussion Paper issued by the South African Revenue Service (hereinafter referred to as SARS) in respect of Interpretation Note 61, included the following important introductory comments: We heartily welcome and endorse the revised approach, which brings the South African interpretation closer to international norm. South Africa is too small an economy in the world to be out of step with the general consensus view, including the views of our main treaty partners (who are mainly OECD members). It also reduces the prospect of having to resort to a mutual agreement procedure; not to mention reducing the likelihood of litigation in the South African courts. South Africa‟s approach to the determination of a legal person‟s place of effective management (hereinafter referred to as POEM) differs from the international approach and has resulted not only in adverse tax implications, but also in a lot of uncertainty for various taxpayers. © 2012 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria Please cite as follows: Jonker, J 2012, "Place of effective management" - a South Africa perspective, LLM dissertation, University of Pretoria, Pretoria, viewed yymmdd < http://upetd.up.ac.za/thesis/available/etd-07252013-120735 / > F13/4/616/gm
Subject(s) Mercantile Law
Language en-uk
Publisher University of Pretoria
Type of publication text
Format application/pdf
Source http://upetd.up.ac.za/thesis/available/etd-07252013-120735/
Rights unrestricted; I hereby certify that, I have obtained and attached hereto a written permission statement from the owner(s) of each third party copyrighted matter to be included in my thesis, dissertation, or project report (
Repository Pretoria - University of Pretoria, Theses and Dissertations
Added to C-A: 2017-03-10;15:13:05