Essays about: "Tax Allocation"

Showing result 1 - 5 of 48 essays containing the words Tax Allocation.

  1. 1. The digital economy and its implications: does the OECD’s Pillar One Proposal challenge the principles of law within International and EU tax law?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Wihan Esterhuizen; [2023]
    Keywords : Tax; EU Law; OECD S Pillar One; principles of law; ability-to-pay; territoriality; state aid; transfer pricing; Arm s length principle; Law and Political Science;

    Abstract : Change is the only constant; yet, as we step into the brave new world of taxing the digital economy, it might seem like the need and development of principles and rules for adequate profit allocation has only begun. This thesis discusses the profit allocation rules under the Unified Approach of the OECD Pillar One Proposal Amount A in relation to three identified principles of law in international and European tax law. READ MORE

  2. 2. 'Preserving a Balanced Allocation of Taxing Powers Between the Member States’ as a Ground of Justification for the Maintenance of Restrictive National Provisions : An analysis of the development of the ground of justification in case law from the CJEU

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Emilia Karlsson; [2023]
    Keywords : ;

    Abstract : The Court of Justice of the European Union (further “CJEU”) assesses the compatibility of national tax provisions with the fundamental freedoms. The assessment normally consists of different steps. The first step is to determine if the national legislation constitutes a restriction. READ MORE

  3. 3. Exchanges of shares and Sweden’s right to tax - An examination of the Swedish exchange of share mechanism for individuals, and its compliance with the Tax Merger Directive

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

    Author : Sam Lincoln; [2023]
    Keywords : EU-rätt; Skatterätt; Law and Political Science;

    Abstract : Den här uppsatsen undersöker den svenska implementeringen av andelsbytesmekanismen för privatpersoner, som återfinns i artikel 8 i Fusions-Direktivet, hädanefter FD. Uppsatsen undersöker även hur Sverige har valt att skydda sin beskattningsrätt när aktieägaren emigrerar till en annan EU MS medan hen äger aktier erhållna via ett andelsbyte. READ MORE

  4. 4. Clashing of two ‘parallel’ legal worlds: the allocation of the right to Tax and the Social security contribution. : The dis-coordination of tax law and social security law specifically witnessed with remote workers: brief analyze of those term and the issues born thereof.

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Sylvie Coralie Gashi; [2022]
    Keywords : Tax law; taxations; tax allocation; territoriality; social security; social security contributions; European Union; remote worker; cross border worker; physical presence test;

    Abstract : In the understanding of the author tax law and social security laws are studied in general separately. The author agrees with many doctrine authors that find it ‘surprising’ as this is a complete and linked issue, that all remote worker even cross-border/frontier workers face. READ MORE

  5. 5. Eu State Aid Rules And Corporate Direct Tax Arrangements : An Analysis of Article 107(1) TFEU and Recent case Developments with the principle of Legality

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Sharon Mame Sika Värttö; [2022]
    Keywords : State aid; Tax ruling; Tax avoidance; Hybrid arrangement; Aid recovery; Legality; Legal certainty; Selective advantage; Harmful tax competition; Transfer pricing; Arm’s length principle; Economic advantage.;

    Abstract : The European Union was devised to promote competition in the international market environment and ensure balanced allocation of fiscal and political requirements of the Member States. Globalization has led to enabling tax environments through granting of tax benefits by EU Member jurisdictions intended to promote competition in attracting foreign investment, trade, and development. READ MORE