Tax, Law and Development
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Tax, Law and Development

Edited by Yariv Brauner and Miranda Stewart

Comprising original essays written by top legal scholars, this innovative volume is the most comprehensive collection to date of independent academic work exploring the relationship between tax, law and development. Contributors cover a range of tax issues, drawing on economic, political, social, and institutional perspectives to offer a comprehensive view of how tax laws affect and are affected by human economic development.
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Chapter 4: Economic development and the role of tax in Southern Africa: the South African headquarter company structure

Tracy Gutuza


In 2010, the concept of a headquarter company structure was introduced in the South African Income Tax. The premise of this development was that South Africa, already the headquarter location for many regional operations of investors, is perfectly suited to be the investment gateway into Southern Africa and that this position could be enhanced with tax and regulatory reforms. This introduction of a headquarter regime, which is in fact a reintroduction, must be understood in the context of the role of South Africa within the African institutional structures and the development of the Southern African region. The Southern African Development Community (SADC)2 Memorandum of Understanding on Co-operation in Taxation and Related Matters states that member countries will cooperate in tax matters and furthermore that member countries will endeavour to avoid harmful tax competition. In addition, the New Partnership for Africa’s Development (NEPAD) provides for the integration of Africa into the global economy and that regional cooperation with integration will be used to address poverty and underdevelopment in Africa. In this regard, NEPAD has identified an African owned frame- work for development as the foundation for partnership at regional and international levels. It envisages, inter alia, economic and investment harmonization and the promotion of intra-African trade and investment. A further factor to consider in the development of the headquarter company structure is South Africa’s recent membership in the alliance between Brazil, Russia, India, China and South Africa, known as the BRICS group. The latter has to be taken into account

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