Essays about: "Direct Taxation"

Showing result 1 - 5 of 64 essays containing the words Direct Taxation.

  1. 1. Is this the end of the Marks & Spencer Doctrine? - The Freedom of Establishment, Permanent Establishments and Objective Comparability

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Ismail Quttineh; [2023]
    Keywords : EU-law; Direct Taxation; Permanent Establishment; Subsidiary; Marks Spencer; Law; Tax; PE; Law and Political Science;

    Abstract : The Thesis examines issues of European Corporate Tax Law and specifically the notion of the Marks & Spencer doctrine, with respect to non-resident permanent establishments. The doctrine entails the possibility for a resident company to deduct losses that were incurred by a PE, situated in another Member State. READ MORE

  2. 2. From Remittances to Development: Exploring Nepal's Path to Progress

    University essay from Lunds universitet/Ekonomisk-historiska institutionen

    Author : Jonathan Damkjær Britton; [2023]
    Keywords : Social Sciences;

    Abstract : Nepal is one of the largest recipients of remittances compared to the size of the economy, reaching 30,1% of GDP in 2018. This makes understanding them, their effects, and how to positively impact that an important policy tool. READ MORE

  3. 3. Head in the sand when trust income is in sight? Analysis of double taxation of trust income originating from dividends in light of Articles 49 and 63 TFEU.

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Madara Olmane; [2023]
    Keywords : tax; Article 49 TFEU; Article 63 TFEU; trusts; fundamental freedoms; EU tax law; comparability; double taxation; trust income; dividends; freedom of establishment; free movement of capital; ECJ; flow-through dividends; coporate income tax; direct taxation; Law and Political Science;

    Abstract : This thesis challenges the treatment of trust income received in a country with no trusts in its legal system in light of freedom of establishment and free movement of capital. Can provisions of a Member State that has decided not to have trusts in its legal system make the transfer of shares or even the establishment of a trust elsewhere less favourable? This question, as the starting point of this thesis, managed to open a Pandora’s box of additional aspects and questions to consider, where each deserves a thesis on its own. READ MORE

  4. 4. 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

  5. 5. Taxing the Digital Economy - A Legal Assessment of the Introduction of PIllar One to the Internal Market

    University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

    Author : Gabija Ramanauskaite; [2021]
    Keywords : EU Law; International tax law; OECD; Pillar One; Nexus; Law and Political Science;

    Abstract : In the last decade, the progress of the digital economy has caused a rift in the international tax regime, which now faces several challenges. The current principles governing taxation rules are based on notions that business can only be conducted through physical presence. READ MORE