Essays about: "BEPS action 7"
Found 2 essays containing the words BEPS action 7.
University essay from Uppsala universitet/Juridiska institutionen
Abstract : The OECD estimates that every year between 100 and 240 billion US dollars of tax revenue is lost due to domestic tax base erosion and profit shifting resulting from the business practices used by multinational enterprises. In 2013, the BEPS Action Plan, encompassing 15 different actions, was sanctioned in response. READ MORE
2. How can the proposed changes to the OECD tax model convention in action 1 and action 7 counter the issue of an artificial avoidance of a PE status?University essay from Lunds universitet/Institutionen för handelsrätt
Abstract : The purpose of this thesis is to clarify how, according to BEPS action 1 and action 7, can the amendments of the “specific activity exemptions” in article 5 paragraph 4 of the OECD Model Tax Convention on Income and Capital (the model convention) counter the issue of an artificial avoidance of a PE status. The main issues that are connected to the concept of a permanent establishment are artificial avoidance of the status of a permanent establishment, the use of transfer pricing rules in order to artificially allocate the profits of a permanent establishment to low tax states and finally that some enterprises that operate within the digital economy can avoid the status of a permanent establishment due to the lack of physical presence. READ MORE