Exit Taxation Arising from a Deemed Disposal of Shares

Journal
Seiler, M.
Luxembourg; South Africa
Bulletin for International Taxation 2013 (Volume 67), No. 11
PriceUSD 45

In this article, the author examines a recent decision of the Supreme Court of Appeal of South Africa (SCA) on the tax treatment of capital gains arising from a deemed disposal of shares under the Luxembourg-South Africa Income and Capital Tax Treaty (1998).