Essays about: "Base Erosion and Profit Shifting"

Showing result 1 - 5 of 23 essays containing the words Base Erosion and Profit Shifting.

  1. 1. 'Preserving a Balanced Allocation of Taxing Powers Between the Member States’ as a Ground of Justification for the Maintenance of Restrictive National Provisions : An analysis of the development of the ground of justification in case law from the CJEU

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Emilia Karlsson; [2023]
    Keywords : ;

    Abstract : The Court of Justice of the European Union (further “CJEU”) assesses the compatibility of national tax provisions with the fundamental freedoms. The assessment normally consists of different steps. The first step is to determine if the national legislation constitutes a restriction. READ MORE

  2. 2. 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 institutionen

    Author : Andrea Rosato; [2022]
    Keywords : tax; international tax; OECD; BEPS; Pillar 2; base erosion; profit shifting; anti-avoidance; corporate inversions; TCJA; tax cuts and jobs act; United States; US; law; US tax law; international tax law; taxation; tax planning; aggressive tax planning;

    Abstract : .... READ MORE

  3. 3. How Multipolarity and Globalization Have Changed the Nature of Tax Multilateralism : A Comparison of the OECD Model Tax Convention Negotiation with the Negotiation of Pillar One and Two

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Daniel Raddenbach; [2022]
    Keywords : tax; taxation; globalization; international relations; negotiation; Pillar One; Pillar Two; OECD; model tax treaty; multilateralism; cooperation; tax multilateralism; global minimum tax; digital services; bilateralism;

    Abstract : Can a multilateral negotiating process—that is, cooperation between many states in a single forum—successfully reform the network of bilateral tax treaties that currently makes up the bulk of international tax law? The BEPS Project aims to be the first major push for a multilateral tax process since the creation of the OECD’s Model Tax Convention in the 1960s. Through BEPS, the OECD and 130-plus countries are in final negotiations to implement Pillar One and Two, which will: (1) create a new taxing right for “market jurisdiction” countries on the profit of international companies that do business there without a physical presence; and (2) implement a top-up tax levied against companies that offshore profits from intangible assets in low-tax jurisdictions. READ MORE

  4. 4. Escaping the Taxman

    University essay from Handelshögskolan i Stockholm/Institutionen för finansiell ekonomi

    Author : Henrik Niklasson; Natasa Vlajic; [2022]
    Keywords : Corporate taxes; Pillar two model; Tax haven; Base erosion and profit shifting;

    Abstract : This thesis studies market effects during time periods when certain information was released concerning the Pillar two model - a law proposal by the OECD intended to combat global tax evasion and raise global corporate tax rates. Several Difference in differences regressions are performed looking both at the market as a whole, as well as an intellectual property intensive subpart of the market. READ MORE

  5. 5. Link between Transfer Pricing and Customs Union Regulations

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Ankita Tiwari; [2022]
    Keywords : Transfer Pricing; Customs Union;

    Abstract : Base erosion and profit sharing (BEPS) explain the process when multinational enterprises take advantage of the gaps, mismatches or loopholes in the international tax regulations for artificially shifting profits to lower tax jurisdictions or no tax jurisdictions. Tax avoidance strategies were legal in most cases and overlooked until the OECD G20 BEPS project was done in 2013. READ MORE