Comparison of the Substantive Aspects of Impermissible Tax Arrangements in South Africa’s General Anti-Avoidance Rule and the Principal Purpose Test in the OECD Model (2017)
Journal
International; OECD; South Africa
Bulletin for International Taxation 2022 (Volume 76), No. 5
This article compares the substantive aspects of impermissible tax arrangements in the South African general anti-avoidance rule and the Principal Purpose Test set out in article 29 of the OECD Model (2017), with emphasis on an evaluation of the examples in the Commentary on Article 29 of the OECD Model (2017).