Foreign employment income: who has the taxing rights? A comparative study on tax provisions in relation to foreign employment income
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Date
2021
Authors
Ngongoma, Buhlebakhe
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Abstract
The cross-border mobility of human capital has resulted in a situation where employees might be
taxed by more than one tax jurisdiction. One tax jurisdiction might tax the employee based on
residency and the other tax jurisdiction might tax based on source. This cross-border mobility
could result in adverse impact on the tax base of a tax jurisdiction if there are no tax provisions
dealing specifically with foreign employment income.
The predominant principle applied internationally by the Organisation for Economic Co- operation
and Development (OECD) countries is that the source of foreign employment income is where the
services are rendered and shall be taxed in the source country unless certain requirements are met.
This research report seeks to interrogate the concept of taxing rights in relation to the foreign
employment income. A comparison between South Africa, Australia, and the United States of America’s
tax provisions in relation to the foreign employment income will be undertaken.
Description
A research report submitted to the Faculty of Commerce, Law and Management, University of the Witwatersrand, in partial fulfilment of the requirements for the degree of Master of Commerce (specialising in Taxation), 2021