Essays about: "Double Tax Convention"

Showing result 1 - 5 of 19 essays containing the words Double Tax Convention.

  1. 1. Taxation of influencers: A double taxation or a non-double taxation issue?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Andrea Del Pilar Valbuena Bernal; [2022]
    Keywords : Taxation; Individual Income Tax; Influencers; International Income Tax; OECD Model Convention.; Law and Political Science;

    Abstract : Although states have begun to regulate influencer activities in areas such as advertising and consumer protection, that is not the case in tax law. This research analyses various Tax Authority’s guidelines on the matter and concludes that the rules already in place in most jurisdictions are applied to influencers’ activities. READ MORE

  2. 2. Comparability Approaches of the CJEU Regards Dividends Received by Non-Resident CIVs: Is the Primary Law Sufficient or Not?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Serra Tor; [2020]
    Keywords : CIV-Investment Fund- Pension Fund-Withholding tax-Discrimination-TFEU Freedoms-Free Movement of Capital-Freedom of Establishment - OECD Model Convention 2017 - OECD s Commentary- UCITS Directive- AIFM Directive; Law and Political Science;

    Abstract : For preventing economic double taxation and neutralization of choice between direct and indirect investments, states might grant domestic funds certain tax advantages while not extending it to non-residents, which possibly result in international double taxation. This issue arises mostly because of the different features of the investment funds. READ MORE

  3. 3. A legal study into the EU’s approach towards exit taxation

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

    Author : Patricia Zakrzewska; [2020]
    Keywords : direct taxation; EU law; exit taxation; ATAD; anti-tax avoidance directive; Law and Political Science;

    Abstract : The purpose of the thesis is to analyse the EU’s and CJEU’s approach towards exit taxes by finding guidance on how the exit tax rules shall be made to be considered as compatible with the requirements of EU law. The EU law’s presumption of establishing an internal market without boundaries at the frontiers prohibits national measures which hinder, inter alia, the market access. READ MORE

  4. 4. Tax Challenges of the Digital Economy: Does a Withholding Tax on Certain Digital Transactions Solve the Problem of Missing Taxation Rights, While Being In Line with EU-Law and the OECD Model Convention?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Nina Kim Rica Sparmann; [2019]
    Keywords : Digital Economy; Withholding Tax; Digital Advertisement Services; User Data; Taxes; Direct Taxation; Tax Challenges of the Digital Economy; OECD; Double Taxation; European Fundamental Freedoms; State Aid; Social Media; Law and Political Science;

    Abstract : This thesis investigates whether the implementation of a withholding tax on financial transactions obtained by the provision of certain digital services could solve the current problem of missing taxation rights regarding the income of highly digitalized multinational business models. Furthermore, the thesis aims to determine whether such tax could be in line with European Union law and the model convention for double taxation treaties issued by the OECD. READ MORE

  5. 5. Hard to value intangibles from a Swedish perspective

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Håkan Vahlsten; [2017]
    Keywords : BEPS Action 8-10; Transfer Pricing; Arm s length principle; Arm s length distance; Inkomstskattelagen; Korrigeringsregeln; Intangibles; Hard To Value Intangibles; HTVI; Law and Political Science;

    Abstract : The purpose of this thesis is to study the work of the OECD presented in the Final BEPS-Report under Action 8 concerning hard to value intangibles in a Swedish context. Further, the OECD Model Tax Convention and its Commentaries are discussed in terms of their validity as a source of law in a Swedish perspective, or if there is a requirement now or after the implementation of Action 8 for changes to the Inkomstskattelagen, and particular the Korrigeringsregeln. READ MORE