3. Electronic Theses and Dissertations (ETDs) - All submissions
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Item Transfer Pricing Documentation in a Post-BEPS environment : a study of the evolution of transfer pricing documentation in South Africa and its alignment with the global standard(2019) Sukhlal, Limahln terms of the South African Income Tax Act 58 of 1962 (“the Act”), the South African Revenue Service (“SARS”) has the power to make transfer pricing adjustments. This arises when SARS deems that Multinational Entities (“MNE”) have been transacting at prices which do not reflect prices expected to be charged if parties to the transaction were independent persons dealing at arm’s-length. By having the ability to make transfer pricing adjustments, SARS can minimise the effects of Base Erosion and Profit Shifting (“BEPS”).1 BEPS refers to tax planning strategies that shift profits from high tax jurisdictions like South Africa to locations where little or no corporate tax is being paid. In order to provide governments with the necessary domestic and international instruments to prevent companies from paying limited amounts of taxes, the Organisation for Economic Co-operation and Development (“OECD”) formulated the BEPS Action Plan at the request of the G20. The BEPS Action Plan consists of 15 Action Points with the objective of minimising or eliminating transactions that erode or decrease a MNE’s tax base by routing its profits from high tax jurisdictions to low tax jurisdictions. The overriding concept of the BEPS Action Plan is that all taxable profits should be taxed once. Among the 15 Action Points addressed in the BEPS Action Plan, Action 13 which provides guidance on transfer pricing documentation and Country-by-Country reporting (“CbCR”), provides one of the bigger challenges to taxpayers in terms of transparency and disclosure This approach to transfer pricing documentation provides tax authorities with relevant and accurate information to perform an effective transfer pricing risk analysis.Item Cameroon's agrarian political economy: impact of the state's free market agrarian system reforms on coffee cooperatives' activities and market orientation.(2018) Ngam, Ronald, NkwainCameroon’s modern economy developed around a satellite-metropolis plantation dynamic within which successive European colonial masters and later, African-led governments, promoted monocrop commodity production along coastal areas for the benefit of Europe. The federating organisations employed to structure production were a combination of plantations, agriculture development zones and especially cooperatives. The period of government-controlled cooperatives was characterised by a too-big-to-fail approach; the State intervened directly in cooperatives’ affairs and managed their cashflow through the National Produce Marketing Board. Following a structural adjustment plan in the 1990s, the Cameroon State divested its interest in cooperatives and transitioned the agrarian system into a borderless, global market within a neoliberal competition state dynamic. This study investigated the impact of the Cameroonian State’s post-structural adjustment neoliberal agrarian system reforms on coffee cooperatives’ activities and market orientation. This was done through the prism of the two biggest coffee cooperatives in Cameroon, i.e. the Central Union of Agricultural Cooperatives of the West (UCCAO) and the North West Cooperative Association (NWCA). The study employed an interpretivist approach, and the extended case methodology was used to gather data. Data gathering instruments included interviews, questionnaires, participant observation, archival material and photos. Respondents were top managers of both cooperatives plus forty coffee growers. The study revealed three key findings. Firstly, the Cameroon State’s support to coffee cooperatives in the free market era is characterised by a preponderance of disparate programmes which appear to be done more for optics rather than actually providing the robust support that is needed to help producer organisations succeed. Some development experts (Chang, 2001; Gereffi, 1995; Stiglitz, 2008) are unanimous that in underdeveloped countries with threadbare infrastructure, the state has a key role to play in providing the infrastructure, communications networks, access to finance and other support necessary to develop efficient value chains that can take commodities to world markets on a consistent and reliable basis. Secondly, Cameroon’s coffee Cooperatives have made only timid and insufficient efforts to adjust to the deeply globalised free market context into which they were suddenly ushered in the 1990s after a half a century of operating as quasi parastatals. Their market orientation shows a business-as-usual approach which is ultimately self-defeating as it stops them from leveraging the opportunities offered by free market globalism. Thirdly, conclusive data from around the world reveals that the more successful modern-day cooperatives are those ones that locate themselves in parallel cooperative market economies based on solidarity, democracy and cooperation among cooperatives rather than in traditional capitalistic value chains (Wright, 2011). It is this pathway that Cameroonian cooperatives need to follow if they wish to succeed in the age of globalism.Item The role of mineral beneficiation in the iron and steel industry: exploiting the linkages in the iron and steel value chain for sustainable development(2018) Radinku, TshegofatsoThe research aims to contribute to the existing debate on whether there is merits in South Africa using abundant mineral resources to industrialise. South Africa has abundant mineral resources and a comparative advantage in the supply and production of mining products such as gold, platinum, coal and iron ore. Despite the comparative advantage in mineral resources, South Africa is characterised by high unemployment rate and a declining manufacturing sector. The research argues that mineral wealth is a blessing and if well managed, mineral resources can spur industrialisation and employment creation. This can be achieved through appropriate policies and strategies that support downstream beneficiation. The research focuses on downstream beneficiation in the iron and steel value chain. The iron and steel value chain is the most important value chain for industrialisation and job creation. The iron and steel products are the most important feedstocks or inputs into the manufacturing sector. The research finds that despite the economic benefits associated with downstream beneficiation, there is currently little value addition taking place in the iron and steel value chain. South Africa exports mainly un-beneficiated or semi-processed iron ore, thus limiting employment creating opportunities. Challenges and constrains to beneficiating the South African iron and steel include: limited access to raw material for local downstream beneficiation, infrastructure bottlenecks, high costs of doing business, shortage of skills and anti-competitive pricing by producers of raw materials and minerals. Policy measures proposed in the research to overcome the challenges and constraints to downstream beneficiation include: better coordination between government departments responsible for industrial policy and mineral beneficiation, greater spending and investment in skill development, upgrading physical infrastructures, reducing the logistics costs and regulating the price of raw materials and minerals.Item South Africa's diplomatic recognition of the people's republic of China: building consensus amongst dissension(2018) Hurst, ClaireThe following research report is an analysis of the diplomatic history paradigm of South Africa’s switch in diplomatic recognition from the Republic of China to the People’s Republic of China in November 1996. Previously classified documentation from the Department of International Relations and Cooperation, and the African National Congress’ Liberation Archives at Fort Hare University, and with interviews with former ANC/National Executive Committee members and Department of Foreign Affairs officials, along with the inclusion of the memoirs of the former ROC and PRC ambassadors at the time of the switch, provide valuable insight into the timing of the announcement and the factors that prompted the decision. This research aims to aid our understanding of the foreign policy decision making process under the Mandela administrationItem The World Bank: a critical analysis of the World Bank's ideological framework: poverty alleviation and development(2017) Ngwendere, SamanthaThis thesis is situated within the study of International Relations. It centers on a critical analysis of the World Bank’s ideological framework towards its poverty reduction and development goals. It seeks to provide an understanding of the ideas, ideals, and values that form the basis of the Bank’s development thinking. Ideology plays an important role in this thesis, as the way the World Bank thinks of and pursues development is of great importance; it speaks to the ideology of development, not just within the Bank, but within the global structure of development. Literature that is reviewed in this thesis suggests that the Bank leans towards a neo-liberal ideology. The selected text for the analysis, The World Development Report: Attacking Poverty (2000-01) will also be analysed in order to review the principles that have been adopted by the Bank and the development community at large. In order to understand and explore the factors that influence the Bank’s ideological framework, this study employs two levels of analysis through a critical theoretical framework and discourse analysis as a methodological tool. The first level of analysis looks at internal sources of influence; the Bank’s voting and governance structure. The second level considers external sources of influence, such as intellectual culture and bureaucratic culture. As stated above, a critical analysis of the Bank’s key document, the World Development Report: Attacking Poverty (2000-01), will also be carried out. This thesis concludes that through internal sources of influences such as the unequal voting shares; powerful actors such as the United States have shaped the Bank’s thinking towards development, as the Bank’s view of development leans towards Anglo-American norms and values as well as interests. Through external sources of influence, the Bank has been dominated by an economic discourse, which Wade (2006) has termed ‘economic imperialism’. Through its hiring, promotion and research publications, the Bank has favored the discourse of economics. Through its financial power within the global arena, the Bank has the power to influence the development narrative, its ideas and values of development have been normalized and universalized within the development community. Its financial strength and research output, both within the Bank and the global arena, are some of its aspect that aid in the maintenance of the status quo in development, consequently, this has led to other views that are not in line with the Bank to be ignored and neglected. The Bank has also presented the neoliberal ideology as the best means to achieve development and alleviate poverty, this is evidenced through the Bank’s key text, as neoliberal principles such as privatisation and deregulation are presented as the only way to achieve development. This thesis also recognises that the Bank does not exists in a vacuum, it ideology, norms and values are also heavily influenced by events that take place on the international sphere, such as the economic crises of the 1970s that influenced the Bank’s position on poverty and development.Item Restraining the developmental state: a comparative institutional study of Botswana and Namibia(2016) Moyo, Kudzai TamukaNatural resources can be a solution to the capital deficit in sub Saharan Africa. As such, resource rich countries have to avoid plundering and wastage of the resource rents. However, the nature of politics in the region points to the fact that plundering of resource rents is inevitable because most resource rich sub Saharan African countries have been prone to elite capture and bad governance. This entails that national resources are “privatised” in the sense that they are directed towards enrichment of a few. In addition, governments in resource rich countries tend to allocate resource rents inefficiently. Thus, resources do not contribute towards sustainable and long-term development. To avoid plundering and wastage, a set of institutions can be put in place that can assist in managing resource rents. These are institutions that can restrain ruling elites from capturing the resource rents for private use and the state from inefficiently allocating rents through policies. Most scholars argue that a democratic system, through frequent elections and its attendant institutions such as the rule of law, accountability and transparency allows effective and efficient management resource rents and the economy in general. This is a good starting point in conceptualising institutions of restraint. However, this study seeks to broaden our understanding of institutions of restraint by providing an alternative approach. Using Botswana and Namibia as case studies this study seeks to reconceptualise institutions of restraint without rejecting the importance of democratic institutions. The study considers the hypothesis that the success in management of resource rents, particularly in Botswana, can be explained by a combination of democratic institutions and what can be termed centralised development planning institutions. The premise of this proposition is that democratic institutions are inadequate in restraining elites or the state. Therefore, they need to be complemented by centralised development planning institutions. Working in tandem, democratic institutions and centralised development planning institutions have the capacity to adequately provide the necessary restraints in resource driven economies. In line with this, the study argues that the degree or level of restraints in a political system is essential for successful management of resource rents.Item The impact of the United States (US) and South Africa's (SA) trade relationship on Botswana, Lesotho, Namibia and Swaziland (BLNS) [1999-2013](2015-08-27) Saule, AsandaThis study set out to interrogate the impact of the U.S. - S.A. trade relationship on Botswana, Lesotho, Namibia and Swaziland (BLNS). A qualitative method of study was chosen and the literature review method was used. South Africa’s foreign policy making was analysed and it was found that in 1994, the country, sought international standing and economic growth. As such, it chose foreign policy that met the stringent criteria of Brenton Woods institutions and liberalised markets, privatised and had a stringent tax regime. The country also carved out a niche as an agent for peace on the African continent and a champion of the global South. South Africa’s post-democratic relationship with the United States was analysed and found to have been negatively impacted by the hangover of Cold War politics and the U.S.’s relationship with the apartheid government. The new government also considered Russia and other American enemies like Cuba, Iran and Lybia allies. The South African government never fully trusted the U.S.’s intentions and was wary of agreeing too often with the country for fear of being called a puppet of the U.S. However, the two countries managed to find common ground and continue to trade with each other successfully. The relationship between BLNS and S.A. in SACU was found to be unequal with BLNS still economically and geographically dependent on S.A. This is in spite numerous changes meant to bring about equality in SACU. The study concluded that there was no real impact on BLNS as a result of the relationship between U.S. and S.A.BLNS suffered a negative impact when the European Union and S.A. signed an agreement but they ensured they were not victims of the U.S. – S.A. trade relationship.