This paper focuses on the agreements and treaties entered into for the relief of income tax, death duties and double taxation of air and sea transport in the period 1932 to 1990. The paper excludes from its scope customs (for example, the Agreement between the Union of South Africa and Southern...

This contribution represents the South African chapter to this comparative work. The book as a whole provides:"Understanding the major trends in tax policy around the world is of great relevance not only for researchers, but also for tax policy makers, government officials and tax practitioners...

This article addresses, in part, the use of the OECD Commentaries with respect to the interpretation of bilateral tax treaties. However, the article has as its focus those instances in which a tax treaty or protocol to a tax treaty, in the main, directly reference the OECD Commentaries as an...

The aim of this article is twofold. The first aim is to provide a comparative overview of the domestic anti-avoidance rules with specific reference to Brazil, Colombia, South Africa and Uruguay to evaluate the application of these rules to tackle aggressive tax planning. The second aim is to...

The main purpose of this book is to promote the dissemination of the basic notions of taxation from a policy, legal and administrative perspective, offering its readers a balanced view of rights and obligations connected with the levying of taxes. The book sets out current principles of taxation...

The Organization for Economic Cooperation and Development (OECD) under Base Erosion and Profit Shifting (BEPS) Action 2 indicated that tax arbitrage via hybrid mismatch arrangements “result in a substantial erosion of the taxable bases of the countries concerned” and “have an overall...