E-commerce: the challenge of virtual permanent establishments
- Adlkofer, Michelle Leigh, Venter, Michelle
- Authors: Adlkofer, Michelle Leigh , Venter, Michelle
- Date: 2015
- Subjects: Organisation for Economic Co-operation and Development , Electronic commerce , Electronic commerce -- Taxation , Double taxation -- Treaties , Globalization
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: vital:921 , http://hdl.handle.net/10962/d1020057
- Description: The continued growth of world commerce has led to the advance of the permanent establishment principles. These principles are, however, constantly challenged by the developments of e-commerce. This thesis considers the taxing of a permanent establishment and the influence of e-commerce on the concept of a permanent establishment. In 2000, the Organisation for Economic Co-operation and Development (“OECD”) developed and introduced guidelines on how to deal with e-commerce in the context of a permanent establishment. Since the OECD guidelines on e-commerce were issued, the permanent establishment principles have come under further scrutiny. The latest development came about in 2013 with the release of the Base Erosion and Profit Shifting (“BEPS”) Action Plan. This Action Plan addresses the intention of the OECD to deal with the taxing of the digital economy. With the development of e-commerce and the result of e-commerce creating intangible boundaries between countries, the concept of a virtual permanent establishment has emerged. This has resulted in the need to tax a presence of an enterprise in a jurisdiction where no actual physical connection can be established. Various authors have made suggestions on how to ensure that an economy in which business is being carried on is correctly compensated for in the form of taxes. The source of income is the driving force for the imposition of taxation today. The main goal of this thesis was to explore the alignment of the concepts of a permanent establishment and e-commerce in the digital economy. This study therefore examined the concepts of both permanent establishments and e-commerce, and explored authors’ views and suggestions on how to deal with the inter-related effects of these two concepts. The relevant Action Points in the OECD Action Plan were also considered. , Maiden name: Venter, Michelle
- Full Text:
- Date Issued: 2015
- Authors: Adlkofer, Michelle Leigh , Venter, Michelle
- Date: 2015
- Subjects: Organisation for Economic Co-operation and Development , Electronic commerce , Electronic commerce -- Taxation , Double taxation -- Treaties , Globalization
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: vital:921 , http://hdl.handle.net/10962/d1020057
- Description: The continued growth of world commerce has led to the advance of the permanent establishment principles. These principles are, however, constantly challenged by the developments of e-commerce. This thesis considers the taxing of a permanent establishment and the influence of e-commerce on the concept of a permanent establishment. In 2000, the Organisation for Economic Co-operation and Development (“OECD”) developed and introduced guidelines on how to deal with e-commerce in the context of a permanent establishment. Since the OECD guidelines on e-commerce were issued, the permanent establishment principles have come under further scrutiny. The latest development came about in 2013 with the release of the Base Erosion and Profit Shifting (“BEPS”) Action Plan. This Action Plan addresses the intention of the OECD to deal with the taxing of the digital economy. With the development of e-commerce and the result of e-commerce creating intangible boundaries between countries, the concept of a virtual permanent establishment has emerged. This has resulted in the need to tax a presence of an enterprise in a jurisdiction where no actual physical connection can be established. Various authors have made suggestions on how to ensure that an economy in which business is being carried on is correctly compensated for in the form of taxes. The source of income is the driving force for the imposition of taxation today. The main goal of this thesis was to explore the alignment of the concepts of a permanent establishment and e-commerce in the digital economy. This study therefore examined the concepts of both permanent establishments and e-commerce, and explored authors’ views and suggestions on how to deal with the inter-related effects of these two concepts. The relevant Action Points in the OECD Action Plan were also considered. , Maiden name: Venter, Michelle
- Full Text:
- Date Issued: 2015
Taxation of non-resident digital companies providing services in South Africa
- Authors: Shumba, Marilyn Tatenda
- Date: 2018
- Subjects: Electronic commerce Taxation Law and legislation South Africa , Value-added tax South Africa , Organisation for Economic Co-operation and Development , Taxation Law and legislation South Africa , Business enterprises, Foreign Taxation Law and legislation South Africa
- Language: English
- Type: text , Thesis , Masters , MCom
- Identifier: http://hdl.handle.net/10962/61680 , vital:28048
- Description: The role played by electronic commerce has increased in recent years and continues to increase. Due to this increase in the buying and selling of digital goods and services, revenue authorities have had to recognise that the existing taxation laws do not adequately tax the digital economy. The goal of this research was to establish how South Africa could amend its fiscal legislation in order to adequately tax the digital economy. The Organisation for Economic Co-Operation and Development (OECD) has been the leader in addressing the challenges posed by the digital economy. The thesis therefore focused on the recommendations by the OECD on how to tax the digital economy and relevant recommendations for South were adopted in this thesis, based on the work of the OECD. The main focus of these recommendations was on implementing the International VAT/GST Guidelines that were drafted by the OECD. The thesis also focused on the progress made by New Zealand with regard to taxing of the digital economy. New Zealand has a similar taxation system to South Africa so that the progress made there was relevant in the South African context. Recommendations were also made, based on the proposals by the New Zealand revenue authority that South Africa could adopt in taxing the digital economy. The main focus of these recommendations was lowering the Value-Added Tax (VAT) registration threshold for non-resident suppliers of electronic services and enacting legislation to provide for registration of an electronic marketplace for VAT purposes, instead of an individual supplier.
- Full Text:
- Date Issued: 2018
- Authors: Shumba, Marilyn Tatenda
- Date: 2018
- Subjects: Electronic commerce Taxation Law and legislation South Africa , Value-added tax South Africa , Organisation for Economic Co-operation and Development , Taxation Law and legislation South Africa , Business enterprises, Foreign Taxation Law and legislation South Africa
- Language: English
- Type: text , Thesis , Masters , MCom
- Identifier: http://hdl.handle.net/10962/61680 , vital:28048
- Description: The role played by electronic commerce has increased in recent years and continues to increase. Due to this increase in the buying and selling of digital goods and services, revenue authorities have had to recognise that the existing taxation laws do not adequately tax the digital economy. The goal of this research was to establish how South Africa could amend its fiscal legislation in order to adequately tax the digital economy. The Organisation for Economic Co-Operation and Development (OECD) has been the leader in addressing the challenges posed by the digital economy. The thesis therefore focused on the recommendations by the OECD on how to tax the digital economy and relevant recommendations for South were adopted in this thesis, based on the work of the OECD. The main focus of these recommendations was on implementing the International VAT/GST Guidelines that were drafted by the OECD. The thesis also focused on the progress made by New Zealand with regard to taxing of the digital economy. New Zealand has a similar taxation system to South Africa so that the progress made there was relevant in the South African context. Recommendations were also made, based on the proposals by the New Zealand revenue authority that South Africa could adopt in taxing the digital economy. The main focus of these recommendations was lowering the Value-Added Tax (VAT) registration threshold for non-resident suppliers of electronic services and enacting legislation to provide for registration of an electronic marketplace for VAT purposes, instead of an individual supplier.
- Full Text:
- Date Issued: 2018
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