The principles governing 'place of effective management' and 'permanent establishments' and their application to the digit al economy: a South African perspective

dc.contributor.authorBoel, Katherine
dc.date.accessioned2022-03-02T11:45:35Z
dc.date.available2022-03-02T11:45:35Z
dc.date.issued2016
dc.descriptionA research report submitted in partial fulfilment of the requirements for the degree of Master of Commerce (Taxation) to the Faculty of Commerce, Law and Management, University of the Witwatersrand, Johannesburg, 2015en_ZA
dc.description.abstractThe purpose of this research report is to consider the application of existing 'place of effective management' (POEM) and 'permanent establishment' (PE) principles to a company operating in a digital economy in order to determine its appropriateness and limitations. This paper is broadly divided into four parts. The first part of the paper provides a brief background to the above taidng principles and the digital economy. The second part considers, in detail, the guidance and factors that are currently available on how the POEM and the creation of a PE for a company may be determined both internationally and from a South African tax perspective, including the role of the residency tie-breaker article and the PE article in most double taxation agreements (DTA's) with South Africa. The third part of the paper considers how these guidelines and factors may apply to the digital economy and the practical challenges which arise. Finally, the paper seeks to identify possible alternatives to overcome the pitfalls in the POEM and PE interpretations and to highlight aspects which require further consideration. en_ZA
dc.description.librarianTL (2022)en_ZA
dc.facultyFaculty of Commerce, Law and Managementen_ZA
dc.identifier.urihttps://hdl.handle.net/10539/32768
dc.language.isoenen_ZA
dc.rights.holderUniversity of the Witswatersrand, Johannesburg
dc.schoolSchool of Accountancyen_ZA
dc.subjectPlace of effective management
dc.subjectThe Organisation for Economic Cooperation and Developmet
dc.subjectKey management and commercial decisions
dc.subjectUCTD
dc.subject.otherSDG-8: Decent work and economic growth
dc.titleThe principles governing 'place of effective management' and 'permanent establishments' and their application to the digit al economy: a South African perspectiveen_ZA
dc.typeDissertationen_ZA
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