A critical commentary and analysis of South African tax legislation affecting the different offshore investment structures that are available to residents.

Abstract

The aim of this dissertation is to provide a detailed and critical commentary on and analysis of South African tax legislation affecting the different offshore business or investment structures available to residents of South Africa so as to establish which is the most tax efficient structure. The different business structures analysed in this dissertation included the following: • Sole proprietorships. • Partnerships. • Companies. • Trusts. The principle provisions of the Income Tax Act dealt with in this dissertation include the following: • Section 9D. • Section 9E. • Section 9F. • Section 25B(2A). • Paragraph 80 of the Eighth Schedule. The following three countries have been selected as countries of investment choice: • The United Kingdom (a ' designated country'). • Kenya (not a ' designated country'). • The Isle ofMan (a tax haven).