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Abstract

This article examines the royalty provisions of South Africa's double taxation agreements in the light of certain emerging issues relating to the tax treatment of the transfer of technology worldwide.

The experience of both Australian and United States tax practices in these areas is drawn upon, as well as the provisions of the 1992 OECD Model Tax Convention, in an attempt to make suggestions for the reform of South Africa's international tax policies at this crucial stage in its development.

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