An Analysis of the Participation Exemption and International Headquarter Regimes in South Africa That Aim to Attract Intermediate Holding Companies and the Interaction Thereof with the OECD’s Pillar Two Proposals

Journal
Author
Brincker, E.
Country
International; OECD; South Africa
Published Date
Issue
Bulletin for International Taxation 2024 (Volume 78), No. 9/10
FormatPDF
EUR
45
| USD
50 (VAT excl.)

This article analyses the incentives that are provided within a South Africa context to attract intermediate holding companies by way of the Participation Exemption and International Headquarter Regimes and discusses the interaction thereof with the OECD’s Pillar Two proposals.