Essays about: "BEPS"
Showing result 1 - 5 of 51 essays containing the word BEPS.
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1. The “saving clause” : Examining the impact on the interpretation of distributive provisions in the OECD Model Tax Convention
University essay from Stockholms universitet/Juridiska institutionenAbstract : .... READ MORE
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2. Problems caused by unilateral measures while taxing the digital economy: Does the value creation approach suggested by OECD solve the problem?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This thesis examines the challenges arising from unilateral measures taken by both developing and developed countries to protect their taxing rights in the digital economy, leading to issues of double taxation. It focuses on India's equalisation levy and the UK's diverted profits tax (DPT) as examples of unilateral measures. READ MORE
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3. Is control over risk getting out of control? : An analysis of the concept of control over risk as set out in the 2022 OECD Guidelines in relation to Swedish law
University essay from Uppsala universitet/Juridiska institutionenAbstract : In 2017 an amended version of the OECD Transfer Pricing Guidelines was published which included new provisions to prevent BEPS through the shifting of risks. Through the amendment of the Guidelines, it was clarified that for an entity in an MNE to contractually assume a risk, for transfer pricing purposes, it needs to control the risk and have the financial capacity to assume it. READ MORE
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4. Targeted interest deduction limitation rules post-Lexel
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
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5. Tax Avoidance, Aggressive Tax Planning, and the United States’ Tax Cuts and Jobs Act of 2017 : An Investigation into Anti-Base Erosion and Anti-Profit Shifting Strategies
University essay from Uppsala universitet/Juridiska institutionenAbstract : .... READ MORE
