Cloud computing activities: South African normal tax source determination

Journal of Economic and Financial Sciences

 
 
Field Value
 
Title Cloud computing activities: South African normal tax source determination
 
Creator Nel, Rudie Steenkamp, Shene
 
Subject Source rules; cloud-computing; originating cause; section 9; income tax
Description The location-independent nature of cloud-based transactions results in many source-related difficulties for normal tax purposes. This study considered the source determination for each of the possible classifications of cloud-based income (lease, service and royalty income, and/or income from know-how) by performing a doctrinal study based on South African and international literature. This study identified and formulated the challenges in applying traditional source tests in the context of cloud-based transactions. These challenges stem from the potential absence of physical presence of the provider in the country of consumption, in contrast to traditional source tests where physical presence indicate a tax presence; as well as the location-independent nature of cloud-based transactions from the perspective of both the provider and the consumer. The findings of the study suggest that the source determination for cloud-based transactions could be based on the source of the payment or residency of the payer, rather than the physical location.
 
Publisher AOSIS
 
Contributor
Date 2016-08-11
 
Type info:eu-repo/semantics/article info:eu-repo/semantics/publishedVersion —
Format application/pdf
Identifier 10.4102/jef.v9i2.57
 
Source Journal of Economic and Financial Sciences; Vol 9, No 2 (2016); 529-544 2312-2803 1995-7076
 
Language eng
 
Relation
The following web links (URLs) may trigger a file download or direct you to an alternative webpage to gain access to a publication file format of the published article:

https://jefjournal.org.za/index.php/jef/article/view/57/54
 
Rights Copyright (c) 2017 Rudie Nel, Shene Steenkamp https://creativecommons.org/licenses/by/4.0
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