Essays about: "Interest Deduction Limitation Rules"
Showing result 1 - 5 of 8 essays containing the words Interest Deduction Limitation Rules.
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1. 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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2. Double Taxation Resulting from the ATAD: Is There A Relief?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Despite of the ambitious aim of the ATAD, the adverse effect of double taxation caused by the implementation of it is unsolved. It is therefore up to taxpayers to solve the conflict of norms by identifying the correct source of law for eliminating double taxation. READ MORE
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3. Thin Capitalization in the OECD, the EU and Sweden: policy responses, evaluation and alternatives.
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : The issue of thin capitalization has risen in importance in recent years, to the point that it warranted international action. That action came in the form of Action 4 of the OECD BEPS Project, of Article 4 of the EU ATAD and of the new interest deduction limitation rules in the national Swedish legislation. READ MORE
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4. Art. 4 ATAD : How the Interest Limitation Rule of the ATAD aligns with the Freedoms of the TFEU and National Constitutions
University essay from Uppsala universitet/Juridiska institutionenAbstract : This thesis addresses Art. 4 ATAD and looks at it from two different angles. Firstly, Art. 4 ATAD will be examined in the light of the TFEU freedoms. READ MORE
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5. To what extent the Anti-abuse measures concerning the interest limitation rule can be introduced into Member States without breaching EU law?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Under the BEPS action 4, the suggested best approach gives guidelines on how Member States can implement the interest limitation rules. The variation of rules and exceptions can facilitate the Member States to introduce the rules or at the same time can expand a gap of an implementation of domestic rules which is not harmonised. READ MORE
