Assessment of administrative burden on South African Controlled foreign company rules relative to the imputation

dc.contributor.authorMatlou, Tracy
dc.date.accessioned2023-09-04T10:25:01Z
dc.date.available2023-09-04T10:25:01Z
dc.date.issued2022
dc.descriptionA research report submitted partial fulfilment of the requirements for the degree of Master of Commerce to the Faculty of Commerce, Law and Management, Wits School of Accountancy, at the University of the Witwatersrand, Johannesburg, 2022
dc.description.abstractSouth African multinational enterprises must comply with the controlled foreign company (CFC) rules in section 9D of the Income Tax Act 58 of 1962 (the Act). The provisions of section 9D of the Act are collectively referred to in this document as CFC rules. The CFC rules are anti-avoidance provisions that discourage South African multinational enterprises from shifting income to foreign companies under their control. This study examines the administrative burden placed on South African multinational enterprises (MNEs) to comply with section 9D of the Act and assesses this administrative burden for reasonableness when compared to the amounts eventually imputed. The study investigates whether South African CFC (SA CFC) rules, which are complex, carry a significant administrative burden on South African MNEs. SA CFC rules are confusing and often are misunderstood by the South African multinational enterprises. This study compares SA CFC rules to the Organisation for Economic Co-operation and Development (OECD), Base erosion and profit shifting (BEPS) action 3’s recommendations for effective CFC rules.
dc.description.librarianPC(2023)
dc.facultyFaculty of Commerce, Law and Management
dc.identifier.urihttps://hdl.handle.net/10539/35845
dc.language.isoen
dc.schoolWits School of Accountancy
dc.titleAssessment of administrative burden on South African Controlled foreign company rules relative to the imputation
dc.typeDissertation
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