Essays about: "Latifa Omri"

Found 1 essay containing the words Latifa Omri.

  1. 1. Limitations on interest deductions: does BEPS action 4 presume tax avoidance?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Latifa Omri; [2016]
    Keywords : Interest; limitations; deductions; BEPS; action 4; tax avoidance; presumption; international tax law; EU law; CJEU; thin capitalization; thin cap rules; anti-tax avoidance; fixed ratio rule; group ratio rule; the best practice approach; fundamental freedoms; case law.; Law and Political Science;

    Abstract : Debt and equity are in most countries treated differently for taxing purposes. The asymmetry between the financing forms are being taken advantage of by MNEs, allowing them to plan their cross-border activities in a way that lowers the taxable burden for the whole group. READ MORE