A critical review of the source and residence principles of taxation of income : a place for both principles in the South African tax system?

摘要

In support of a short dissertation entitled -"A critical review of the source and residence principles of taxation of income : Aplace for both principles in the South African tax system?"QbjeetivesTo review and critically examine the application of the source and reside.nce principles regardingthe taxption of income in South Africa, and to reveal the extent of the existence and application ofa hybrid tax system in respect of the source and residence principles. To examine the legalprinciples and policy considerations arising from the existence of a hybrid tax system, inter alia, inthe context of the Fifth Interim Report of the Katz Commission and consequent legislativedevelopments. with a view to recommending. where appropriate, tax reform.Methodology iDd AQProachA review of relevant authority,liter@ture, principles and legislation.ConclusionTo draw conclusions and recommendations regarding the merits of adopting a hybrid system inSouth Africa and, where appropriate, recommend legislative reforms particularly with regard tobusiness income.