Silke on International Tax
An online reference on international tax comprising a collection of chapters on the the OECD convention by respected experts, reviewed by Judge Dennis Davis.
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Product description
An online reference on international tax comprising a collection of chapters on the the OECD convention by respected experts, reviewed by Judge Dennis Davis.
Contains a unique collection of forty-eight chapters written by leading international tax law scholars and practitioners, including Michele Benetello, Anne Bennett, Adv Julia Boltar, Adv Chris Cilliers, David Clegg, Peter Dachs, Alwyn de Koker, Dr Charl du Toit, Adv Gavin Goldman, Adv Johann Hattingh, Wally Horak, Andrew Lewis, Ernest Mazansky, Natalie Napier, Le Roux Roelofse, Adv Peter Solomon SC, Prof RC (Bob) Williams, Prof Lindsay Mitchell. The emphasis falls on current practice and the challenges facing South African practitioners.
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Table of contents
Chapter 1 - Introduction
Chapter 2: - Jurisdiction to tax
Chapter 3: - Controlled Foreign Companies
Chapter 4: - Foreign Dividends
Chapter 5 - Trust International
Chapter 6 - Foreign Exchange Gains and Losses
Chapter 7: - Foreign Exchange Gains and Losses
Chapter 8: - Financial Instruments
Chapter 9: - Beneficial ownership and double tax conventions (with appendix)
Chapter 10 -
Chapter 11 - Payment of International Tax obligations
Chapter 12 - Legal Nature and Scope of Application of Double Taxation Agreements
Chapter 13 - The legal nature of and scope of application of double taxation agreements concluded by South Africa
Chapter 14 - Persons covered
Chapter 15 - Taxes covered
Chapter 16 - General definitions
Chapter 17 - Resident
Chapter 18 - Permanent Establishments
Chapter 19 - under review
Chapter 20 - Business profits
Chapter 21 - Shipping, inland waterways and air transport
Chapter 22 - Associated enterprises
Chapter 23: - Dividends declared by a South African company to a non-resident shareholder
Chapter 24 - Interest
Chapter 25 - Royalties
Chapter 26 - Capital Gains
Chapter 27 - Independent personal services
Chapter 28 - Income from Employment
Chapter 29 - Director’s Fees
Chapter 30 - Entertainers and Sportspersons
Chapter 31 - Pensions and annuities
Chapter 32 - under review
Chapter 33 - under review
Chapter 34 - Other income
Chapter 35 - under review
Chapter 36 - Elimination of International Double Taxation
Chapter 37 - Non-discrimination
Chapter 38 - Mutual Agreement Procedure
Chapter 39: - Exchange of Information
Chapter 40 - Assistance in the Collection of Taxes
Chapter 41 - under review
Chapter 42 - new chapter being drafted
Chapter 43 - Territorial extension
Chapter 44 - Entry into force
Chapter 45 - Termination
Chapter 46 - Ancillary articles
Chapter 47 - Anti-avoidance
Chapter 48 - Repatriation of profits on inbound and outbound investments
