The Application and Interpretation by South African Courts of General Renvoi Clauses in South African Double Taxation Agreements
General renvoi clauses in DTAs based on article 3(2) of the OECD MTC provide that an undefined term in a DTA shall have the meaning that it has in the domestic law of the contracting state applying the DTA unless the context otherwise requires. All South African DTAs include such a clause. Many i...
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Format: | Article |
Language: | Afrikaans |
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North-West University
2019-11-01
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Series: | Potchefstroom Electronic Law Journal |
Subjects: | |
Online Access: | https://journals.assaf.org.za/index.php/per/article/view/4402 |