Action 4 of the OECD/G20 Base Erosion and Profit Shifting Project and the Non-Discrimination Clauses in South Africa’s Tax Treaties

Abstract

In this article, the author considers the implications of Action 4 of the OECD/G20 Base Erosion and Profit Shifting Project in relation to the non-discrimination clauses in the tax treaties that South Africa has concluded and how it impacts the country’s domestic legislation enacted to advance the goals of Action 4.