References

• 1994The Constitution of the Republic of South Africa4,191 cited
• 2011Vienna Convention on the Law of Treaties562 cited
• 2004Interpretation of Tax Treaties Under International Law81 cited
• 2014The Use of OECD Commentaries as Interpretative Aids - The Static/Ambulatory–Approaches Debate Considered from the Perspective of International Law49 cited
• 2008International tax planning and prevention of abuse : a study under domestic tax law, tax treaties and EC law in relation to conduit and base companies40 cited
• 1999Beneficial Ownership of Royalties in Bilateral Tax Treaties25 cited
• 2015Tax Treaty Override and the Need for Coordination between Legal Systems: Safeguarding the Effectiveness of International Law21 cited
• 2013Exit Charges for Migrating Individuals and Companies: Comparative and Tax Treaty Analysis14 cited

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