An Analysis of the Participation Exemption and International Headquarter Regimes in South Africa That Aim to Attract Intermediate Holding Companies and the Interaction Thereof with the OECD’s Pillar Two Proposals

This article analyses the incentives that are provided within a South Africa context to attract intermediate holding companies by way of the Participation Exemption and International Headquarter Regimes and discusses the interaction thereof with the OECD’s Pillar Two proposals.