Die belasting van buitelandse dividende in die Republiek van Suid-Afrika

[摘要] ENGLISH ABSTRACT: The introduction of section 9E in the Income Tax Act, NO.58 of 1962 (hereafterthe Act) became effective on 23 February 2000.The main reasons for the introduction of this was, inter alia, to broaden the taxbase and to phase in the residency basis of taxation. Consequently are theforeign dividend rules of section 9E interrelated to the foreign income rules ofsection 90, being the application of the residence basis of taxation.The main objective of this study is to investigate the taxation of foreigndividends in the Republic of South Africa.The introduction of section 9E saw new terminology introduced, which needanalysis. This analysis is made possible by supplying the definitions from theAct, as well as making use of national and international case law.Further investigation is also done as to the relevance of section 9E to othersections in the Act, relevant anti-avoidance rules regarding foreign dividends,the effect of section 9E on investment income from tax havens, with specificreference to natural persons, the effect of taxation of foreign dividends on themigration- and investment decisions of non-residents, relief providedregarding double taxation and section 9E's effect on secondary taxation oncompanies. Lastly, the collection of taxation on foreign dividends isinvestigated.

[发布机构] Stellenbosch University