Cloud computing activities: Guidelines on the South African income tax classification

Journal of Economic and Financial Sciences

 
 
Field Value
 
Title Cloud computing activities: Guidelines on the South African income tax classification
 
Creator Steenkamp, Shené Nel, Rudie
 
Subject Income tax classification; section 9 of Income Tax Act; Cloud computing; Know-how; Lease; Intellectual property; Royalties
Description The classification of income from cloud computing activities, according to the substance-over-form doctrine, is fundamental to the application of the correct taxation source test. The designation of IaaS, PaaS and SaaS, the three main cloud computing service models, clearly denotes the form of cloud computing activities as that of a service. However, the nature of cloud computing inherently raises the question of whether or not cloud computing income should not rather be classified as income from leasing activities or the imparting of know-how. In fact, the findings of this study suggest the classification would not necessarily always be that of a service. The possible classification as lease income can be either income from the lease of tangible computer hardware and/or of intellectual property (royalty income). The aim of this study was to formulate guidelines to assist in the correct classification of income from cloud computing activities. This was achieved by performing doctrinal research based on the South African and international literature.
 
Publisher AOSIS
 
Contributor
Date 2016-03-10
 
Type info:eu-repo/semantics/article info:eu-repo/semantics/publishedVersion —
Format application/pdf
Identifier 10.4102/jef.v9i1.39
 
Source Journal of Economic and Financial Sciences; Vol 9, No 1 (2016); 228-243 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/39/36
 
Rights Copyright (c) 2017 Shené Steenkamp, Rudie Nel https://creativecommons.org/licenses/by/4.0
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