South African double tax treaties: Royalty reform in the light of the Australian experience

Research output: Contribution to journalArticleResearchpeer-review

Abstract

This article examines the royalty provisions of South Africa's double taxation agreements in the light of certain emerging issues relating to the tax treatment of the transfer of technology worldwide.
The experience of both Australian and United States tax practices in these areas is drawn upon, as well as the provisions of the 1992 OECD Model Tax Convention, in an attempt to make suggestions for the reform of South Africa's international tax policies at this crucial stage in its development.
Original languageEnglish
Pages (from-to)55-81
Number of pages27
JournalRevenue Law Journal
Volume5
Issue number1
Publication statusPublished - 1995
Externally publishedYes

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taxes
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OECD

Cite this

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title = "South African double tax treaties: Royalty reform in the light of the Australian experience",
abstract = "This article examines the royalty provisions of South Africa's double taxation agreements in the light of certain emerging issues relating to the tax treatment of the transfer of technology worldwide.The experience of both Australian and United States tax practices in these areas is drawn upon, as well as the provisions of the 1992 OECD Model Tax Convention, in an attempt to make suggestions for the reform of South Africa's international tax policies at this crucial stage in its development.",
author = "Michelle Markham",
year = "1995",
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volume = "5",
pages = "55--81",
journal = "Revenue Law Journal",
issn = "1034-7747",
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South African double tax treaties : Royalty reform in the light of the Australian experience. / Markham, Michelle.

In: Revenue Law Journal, Vol. 5, No. 1, 1995, p. 55-81.

Research output: Contribution to journalArticleResearchpeer-review

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AB - This article examines the royalty provisions of South Africa's double taxation agreements in the light of certain emerging issues relating to the tax treatment of the transfer of technology worldwide.The experience of both Australian and United States tax practices in these areas is drawn upon, as well as the provisions of the 1992 OECD Model Tax Convention, in an attempt to make suggestions for the reform of South Africa's international tax policies at this crucial stage in its development.

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