Beneficial ownership provisions in tax treaties between developed and developing countries: the Canada/South Africa example

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dc.contributor.authorSteenkamp, Lee-Ann
dc.date.accessioned2017-02-20T11:59:38Z
dc.date.available2017-02-20T11:59:38Z
dc.date.issued2013
dc.description.abstractIn the years since the Organisation for Economic Cooperation and Development (OECD) adopted its first draft tax treaty in 1963, the world has experienced an astonishing surge in international trade and investment. The tax treatment of these cross-border transactions is affected by double tax agreements. As tax treaty networks will likely continue to expand, concerns about tax treaty abuse might be expected to grow. The extent to which a country’s tax treaty policy favours developing countries - or not - depends upon the extent to which the country is prepared to adopt provisions from the UN model tax convention as opposed to the OECD model. Developing countries, in particular, should carefully consider the design of their tax treaties so as to effectively combat tax avoidance without sacrificing foreign direct investment. To this end, the Canada/South Africa tax treaty is compared and contrasted with these two models. The concept of beneficial ownership is reviewed in this context. It is contended that a general definition in South Africa's Income Tax Act of 'beneficial ownership' would assist in the interpretation of the term for the purposes of South Africa's tax treaties. It is submitted that the scope for the source taxation of passive investment income (viz. dividends, interest and royalties) in the developing country could be magnified through treaty negotiations.en_US
dc.description.accreditationInternational Bibliography of Social Sciences
dc.identifier.citationSteenkamp, L. (2013). Beneficial ownership provisions in tax treaties between developed and developing countries: the Canada/South Africa example. International Business and Economics Research Journal, 12(9): 1107-1118en_US
dc.identifier.issn1535-0754
dc.identifier.urihttp://hdl.handle.net/10566/2559
dc.identifier.urihttp://dx.doi.org/10.19030/iber.v12i9.8056
dc.language.isoen_USen_US
dc.privacy.showsubmitterFALSE
dc.publisherClute Instituteen_US
dc.rightsCopyright by author(s) Creative Commons License CC-BY. Users (which include among others, readers, authors, institutions, universities, libraries, organizations, associations, government entities etc) are allowed to read, download, copy, distribute, remix, tweak, build upon, print, search, or link the full text of the articles in this journal provided that appropriate credit is given.
dc.status.ispeerreviewedTRUE
dc.subjectBeneficial ownershipen_US
dc.subjectTax Treatiesen_US
dc.subjectSouth Africaen_US
dc.subjectCanadaen_US
dc.titleBeneficial ownership provisions in tax treaties between developed and developing countries: the Canada/South Africa exampleen_US
dc.typeArticleen_US

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