Essays about: "BEPS"

Showing result 1 - 5 of 15 essays containing the word BEPS.

  1. 1. BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty - Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Johanna Fridh; [2016]
    Keywords : tax treaty override; Tax treaty; improper use of a tax treaty; anti-abuse rules; Limitation-on-benefits; Principal purpose test; General Anti-avoidance rules; BEPS; Action 6; agressive tax planning; Law and Political Science;

    Abstract : The thesis provides an overview of the relationship between tax treaties and domestic law and issues that arise if a contracting state uses domestic anti-avoidance rules to prevent the improper use of a tax treaty. Improper use of a tax treaty is an issue addressed in the BEPS Action 6 report. READ MORE

  2. 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

    Author : Maria Wettersten; [2016]
    Keywords : BEPS action 1; Permanent establishment; BEPS action 7; artificial avoidance; Law and Political Science;

    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

  3. 3. International corporate taxation and developing economies: is global tax harmonization desirable and feasible?

    University essay from Lunds universitet/Ekonomisk-historiska institutionen

    Author : David Palomera Zaidel; [2016]
    Keywords : corporate tax; International taxation; tax avoidance; tax competition; tax harmonization; Social Sciences; Business and Economics;

    Abstract : Greater capital mobility and financial integration have generated greater tax avoidance and international tax competition. This has modified negatively the tax systems of countries that keep taxing corporate profits: the system is now more inefficient, might be more regressive and tax authorities have less sovereignty. READ MORE

  4. 4. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Margret Agusta Sigurdardottir; [2016]
    Keywords : Taxation; Tax; Tax Law; Direct Taxation; Fundamental Freedoms; Double Taxation; Double Non-Taxation; Tax Avoidance; Aggressive Tax Planning; The Single Tax Principle; Single Taxation; Tax Treaty Law; GAAR; General Anti-Abuse Rule; Exemption Method; Credit Method; Dividend; Interest; Classification of Income; International Tax Regime; ECJ Case Law; Hybrid Mismatch Arrangements; Hybrid Financial Instruments; Parent-Subsidiary Directive; Base Erosion and Profit Shifting; BEPS; BEPS Action Plan 2; Anti-Hybrid Rules; Linking Rules; Correspondence Principle; Anti-Tax Avoidance Directive Proposal; Parent-Subsidiary Directive Amendments; Justification Grounds; EU Law; Law and Political Science;

    Abstract : The purpose of the thesis is to analyse the problems of hybrid mismatch arrangements within the EU and how single taxation, which requires income to be taxed once, not more or less, can be secured under EU law. After the amendments of the Parent-Subsidiary Directive (PSD), where an anti-hybrid rule was enacted, the legal environment for companies within the European Union changed. READ MORE

  5. 5. Does the LOB clause in BEPS Action 6 violate the principle of MFN treatment in EU law?

    University essay from Lunds universitet/Juridiska institutionen

    Author : Sascha Åkerman; [2016]
    Keywords : EU law; tax law; BEPS; tax planning; tax avoidance; aggressive tax planning; LOB clause; LOB rule; limitation on benefit; MFN treatment; MFN principle; principle of MFN treatment; ACT Group Litigation case; Sopora case; D case; Orange European Smallcap Fund case; WTO; GATT; Law and Political Science;

    Abstract : OECD delivered on October 5th 2015 the BEPS final package consisting of 15 actions intending to address the issues of base erosion and profit shifting. The aim of Action 6 is to prevent treaty abuse, in particular treaty shopping. READ MORE