The article deals with the interesting issue of the tax treaty qualification problems arising in hybrid financial instruments and structures. The need to fit the great diversity of instruments and legal, economic and accounting trends attached to them into the closed range of treaty income...

Out of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric and 59% are asymmetric, i.e., they prescribe different dividend withholding tax rates (WTRs) depending on the foreign investor's ownership fraction. The paper investigates the reasons for this phenomenon, namely why...

This study investigates the impact of residence country’s double tax relief method and of tax sparing agreements, on the difference between developing countries’ withholding taxes under domestic law, and negotiated withholding taxes in tax treaties with OECD member states. Using a dyadic...

This book chapter traces the events of 1914 that led to the imposition of income tax in South Africa. Based on historical records, it explains the economic and political circumstances that appeared to motivate the first Union government to introduce an income tax. General Jan Smuts, then...

The book chapter charts a complex of ideas about how corporate and shareholder income was and ought to have been taxed over the course of the first half century of income taxation in South Africa (1914-1953). In this period, at least six phases with distinct patterns can be discerned. A close...