n SA Mercantile Law Journal = SA Tydskrif vir Handelsreg - Has recent United Kingdom case law affected the interplay between 'place of effective management' and 'controlled foreign companies'? : analysis

Volume 24, Issue 4
  • ISSN : 1015-0099
  • E-ISSN: 1996-2185



The approach to locating the 'place of effective management' as the test for the tax residency of a company in the South African context has yet to be determined, simply because the phrase is not defined in the Income Tax Act and its interpretation in the context of a company has not come before a South African court.

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