Analysis of misuse and abuse in terms of the South African general anti-avoidance rule : lessons from Canada
Why this work is in the frame
A frame that forgets how it found something cannot be audited. These are the routes that admitted this work.
Bibliographic record
Abstract
In terms of the South African general anti-avoidance rule, a transaction that \nmisuses or abuses the provisions of the Income Tax Act may be disregarded \nfor tax purposes. The misuse or abuse provision, along with the general antiavoidance \nrule (GAAR), has not yet been judicially considered. It is argued \nthat the provision brings further uncertainty and breadth to the general antiavoidance \nrule. It calls for a purposive interpretation of tax legislation. This \napproach, however, creates uncertainty regarding the determination of \npurpose. In Canada, from which the provision was borrowed, the courts \ninitially applied a policy approach in determining purpose but this \ndisadvantaged the revenue authorities in a series of cases. The Minister of \nNational Revenue was required to present a clear and unambiguous policy \nwhich in reality could not be found. The thrust of this article is to show that \nthe misuse or abuse concept could turn out to be a lateral development in the \nSouth African GAAR because of the uncertainty it carries and if lessons on \nits application are not learned from the Canadian experience.
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Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.000 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.000 | 0.000 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it