n SA Mercantile Law Journal = SA Tydskrif vir Handelsreg - The challenges that e-commerce poses to international tax laws : 'controlled foreign company legislation' from a South African perspective (part 1)

Volume 20, Issue 3
  • ISSN : 1015-0099
  • E-ISSN: 1996-2185



Faced with high rates of tax in their countries of residence, taxpayers involved in international trade are increasingly developing global tax avoidance strategies, in order to maximise profits. For most businesses, the possibility of reducing tax costs by basing a business offshore in a low tax jurisdiction is an inherent aspect of international tax planning. Where a company is based in an offshore jurisdiction, it is not subject to domestic tax until its income is distributed to the shareholders as dividends.

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