Essays about: "Anti-Avoidance Rules"

Showing result 11 - 13 of 13 essays containing the words Anti-Avoidance Rules.

  1. 11. Linking Rules Assessed Against European and National Legal Benchmarks - A Juridical Remedy to Mitigate Double Non-Taxation?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Oliver Frank; [2015]
    Keywords : Hybrid instruments; Linking Rules; BEPS; Action 2; OECD; Primary Rule; Secondary Rule; § 8b KStG; Law and Political Science;

    Abstract : This thesis provides a comprehensive analysis of linking rules, which were adapted as one of the alleged remedies against base erosion by the EU and the OECD. A number of issues emerge in connection with those recommended rules. This thesis will thus assess compliance of those rules against domestic and European legal benchmarks. READ MORE

  2. 12. Applicability of domestic anti-avoidance legislation in relation to tax treaty commitments - A case study placing Swedish law in an international doctrinal framework

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Anna Sandin; [2013]
    Keywords : Double tax treaty; Domestic law; GAAR; International doctrine; Anti-avoidance legislation; Treaty-abuse; Law and Political Science; Business and Economics; Social Sciences;

    Abstract : The present paper is an analysis of Swedish law, as expressed obiter dictum in the Supreme Administrative Court decision of HFD 2012 ref. 20, regarding applicability of Swedish general anti avoidance rules in relation to tax treaty commitments. The purpose of the paper is to put Swedish law, as envisaged by HFD 2012 ref. READ MORE

  3. 13. Treaty shopping

    University essay from Lunds universitet/Juridiska institutionen

    Author : Andreas Nyberg; [2002]
    Keywords : Skatterätt; Law and Political Science;

    Abstract : The expression treaty shopping is of American origin and it is closely related to the term forum shopping, a term used in U.S. civil procedure. Forum shopping describes a behaviour by which a party in a court case tries to ''shop'' into a jurisdiction or circuit where he expects a more favourable decision to be given. READ MORE