Essays about: "ATAD"

Showing result 1 - 5 of 21 essays containing the word ATAD.

  1. 1. Targeted interest deduction limitation rules post-Lexel

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Alexander Tale; [2022]
    Keywords : Tax; EU; European Union; Interest; Targeted interest deduction rules; CIT; Coporate income tax; BEPS; OECD; Pillar Two; DEBRA; ATAD; IRD; Lexel; SIAT; Thin Cap; Deduction; Sweden; Court of Justice; Business law; Business and Economics; Law and Political Science;

    Abstract : The need for targeted interest deduction rules is far from over. Most recently targeted interest deduction limitation rules have been presented in the proposal for a Directive implementing OECD Pillar Two in the EU, as well as in the proposal for a Directive on debt-equity bias reduction allowance. READ MORE

  2. 2. Does the deferred payment method of Art. 5 ATAD provide for a technique proportionate to mitigate liquidity disadvantages of exit taxes?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Sven Uetermeyer; [2021]
    Keywords : exit tax; exit taxation; ATAD; tax avoidance; deferred payment; deferral; liquidity disadvantage; Law and Political Science;

    Abstract : This thesis analyses the deferred payment method of Art. 5 para. 2 ATAD. It asks whether or not it is proportionate to mitigate liquidity disadvantages stemming from exit taxes. READ MORE

  3. 3. (E)merging value decreases in transferred assets - A study on tax aspects regarding post-merger value decreases in assets transferred upon merger

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Dennis Zotterman; [2020]
    Keywords : ATAD; Exit Tax; Merger; Merger Directive; Realised Loss; Step-Up in Tax Base; Transferred Assets; Law and Political Science;

    Abstract : The objective of this thesis has been twofold. Firstly, the purpose has been to examine how the outcomes for tax purposes, at the company level, differ depending on whether the assets transferred in a merger remain attributable to a P.E. READ MORE

  4. 4. The incompatability of art. 4 ATAD with freedom of establishment: Evidence from the Swedish implementation

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Richard Påhlsson; [2020]
    Keywords : Anti-Tax Avoidance Directive; ATAD; ATAD art 4; Interest limitation rules; Tax avoidance; Tax abuse; Transposition of EU directives.; Law and Political Science;

    Abstract : The Anti-Tax Avoidance Directive calls for a new chapter in the fight against tax avoidance and abuse in the European Union - as a minimum level of protection against tax avoidance practises is established. Member States have a certain degree of discretion when implementing the directive. READ MORE

  5. 5. In What Way Does the Russian GAAR Comply With EU ATAD and BEPS Rules?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Aleksei Shcherbakov; [2020]
    Keywords : Tax law; tax abuse; GAAR; ATAD; BEPS; CFC; EU law; Russian tax law; tax avoidance; Law and Political Science;

    Abstract : The issues of tackling aggressive tax planning are actual throughout the whole history of global market economy. Earlier this struggle was held by the states individually through imposing rules into their national legislation authorizing tax supervisory bodies to use new methods of control, establishing liability for tax evasion, and developing the approaches by judgements of the courts on relevant cases. READ MORE