Essays about: "Limitation-on-benefits"
Found 5 essays containing the word Limitation-on-benefits.
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1. BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty - Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The thesis provides an overview of the relationship between tax treaties and domestic law and issues that arise if a contracting state uses domestic anti-avoidance rules to prevent the improper use of a tax treaty. Improper use of a tax treaty is an issue addressed in the BEPS Action 6 report. READ MORE
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2. The Compatibility of Limitation on Benefits Provisions in Tax Treaties with EC Law
University essay from Lunds universitet/Juridiska institutionenAbstract : Most bilateral tax treaties contain provisions with the objective of preventing different types of treaty abuse. Limitation on benefits clauses are an example of such provisions, and are generally found in United States tax treaties. These include various tests, which need to be fulfilled by a taxpayer wishing to enjoy the benefits of a tax treaty. READ MORE
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3. Most-Favoured-Nation Treatment in an EC Tax Law Perspective - A Special Focus on the Principle's Effect on the Limitation on Benefits Clauses in Double Taxation Conventions
University essay from Lunds universitet/Juridiska institutionenAbstract : The Most-Favoured-Nation treatment has been a common feature in international economic relations for a long period of time. The principle provides for equal competitive opportunities between contracting states and has been a standard in the field of trade, investment and other areas of economic co-operation. READ MORE
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4. Treaty shopping
University essay from Lunds universitet/Juridiska institutionenAbstract : The expression treaty shopping is of American origin and it is closely related to the term forum shopping, a term used in U.S. civil procedure. Forum shopping describes a behaviour by which a party in a court case tries to ''shop'' into a jurisdiction or circuit where he expects a more favourable decision to be given. READ MORE
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5. The United States Fight Against Harmful Tax Competition
University essay from Lunds universitet/Juridiska institutionenAbstract : The United States taxes its citizens on their worldwide income. Since the U.S. taxpayers are not always very complaisant the government has had to create ways to disclose and control transactions and penalise non-compliant taxpayers. READ MORE
