oa Comparative and International Law Journal of Southern Africa - Fiscal domicile in the Law of Double Taxation agreements

Volume 3, Issue 1
  • ISSN : 0010-4051



The term "Fiscal Domicile" is not self-explanatory. "Fisc" may be understood as that branch of the Government which is expressly charged with the collection of revenue, but not as the Government in its general sense. Does, then, the term "Fiscal Domicile" refer to a domicile of the fiscus or does it rather suggest a domicile of the taxpayer for fiscal purposes ? The answer must be gathered from the article of the Double Taxation Agreement which bears that title, due regard being had to the context.

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