Botha, Carli
The impact of multilateral and unilateral measures on profit-shifting from South Africa to Mauritius / Carli Botha, Roshelle Ramfol & Odette Swart
Resumen.
This article reviews the implementation of the BEPS Action Plan by both jurisdictions, namely Mauritius (as a low tax jurisdiction) and South Africa (as a high tax jurisdiction). The success of the BEPS Action Plan in curbing profit-shifting practices from South Africa to Mauritius is measured in conjunction with the South African anti-avoidance legislation. The findings highlight that only Action 5 has been successfully adopted by both South Africa and Mauritius. A preliminary analysis was conducted which indicates that the implementation of the BEPS Project will not result in less profit-shifting, due to gaps in the South African anti-avoidance legislation that facilitates these profit-shifting practices. It is suggested that the implementation of the BEPS Action Plan by higher tax jurisdictions should be prioritized.
EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS
ELUSION FISCAL
EVASION FISCAL
PREVENCIÓN
PROGRAMAS
APLICACION
MAURICIO
SUDAFRICA
Ramfol, Roshelle
Swart, Odette
Intertax 0165-2826 v. 51, n. 3, March 2023, p. 232-249
The impact of multilateral and unilateral measures on profit-shifting from South Africa to Mauritius / Carli Botha, Roshelle Ramfol & Odette Swart
Resumen.
This article reviews the implementation of the BEPS Action Plan by both jurisdictions, namely Mauritius (as a low tax jurisdiction) and South Africa (as a high tax jurisdiction). The success of the BEPS Action Plan in curbing profit-shifting practices from South Africa to Mauritius is measured in conjunction with the South African anti-avoidance legislation. The findings highlight that only Action 5 has been successfully adopted by both South Africa and Mauritius. A preliminary analysis was conducted which indicates that the implementation of the BEPS Project will not result in less profit-shifting, due to gaps in the South African anti-avoidance legislation that facilitates these profit-shifting practices. It is suggested that the implementation of the BEPS Action Plan by higher tax jurisdictions should be prioritized.
EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS
ELUSION FISCAL
EVASION FISCAL
PREVENCIÓN
PROGRAMAS
APLICACION
MAURICIO
SUDAFRICA
Ramfol, Roshelle
Swart, Odette
Intertax 0165-2826 v. 51, n. 3, March 2023, p. 232-249