Essays about: "armlängdsprincipen"

Showing result 1 - 5 of 14 essays containing the word armlängdsprincipen.

1. 1. Is control over risk getting out of control? : An analysis of the concept of control over risk as set out in the 2022 OECD Guidelines in relation to Swedish law

   University essay from Uppsala universitet/Juridiska institutionen

   Author : Karolina Linusson; [2023]
   Keywords : control over risk; OECD Transfer Pricing Guidelines; transfer pricing; the arm s length principle; kontroll över risk; internprissättning; armlängdsprincipen;

   Abstract : In 2017 an amended version of the OECD Transfer Pricing Guidelines was published which included new provisions to prevent BEPS through the shifting of risks. Through the amendment of the Guidelines, it was clarified that for an entity in an MNE to contractually assume a risk, for transfer pricing purposes, it needs to control the risk and have the financial capacity to assume it. READ MORE

3. 2. The Grey Area of Taxation - An essay on Low Value-Adding Services in Swedish Tax Law

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

   Author : Douglas Linton Wahlgren; [2023]
   Keywords : skatterätt; finansrätt; koncerninterna tjänster; internprissättning; vinstallokering; Law and Political Science;

   Abstract : This essay critically examines the legal aspects of low value-adding services within multinational corporations, focusing on their treatment in Swedish tax law and the OECD Transfer Pricing Guidelines (OECD TPG). It explores the challenges and complexities involved in defining and taxing intragroup services, emphasizing their impact on profit shifting strategies. READ MORE

4. 3. Addressing Aggressive Tax Planning through Unitary Tax or Self-Regulation- A Study on the Possible Need for an International Tax Reform

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

   Author : Astrid Bendixen Kettis; [2020]
   Keywords : International Tax Law; Corporate Taxation; CSR; Law and Political Science;

   Abstract : Domestic and international regulations aiming to facilitate international trade and investment today enable multinational corporations (MNCs) to operate transnationally through the use of branches or subsidiary companies. Within the field of corporate taxation, the lack of a global and universal tax system regulating international tax matters however allows MNCs to exploit gaps and loopholes within such regulations to lower or even eradicate their tax burden. READ MORE

5. 4. The Seeking of a Business-Optimal Transfer Price - In accordance with the Arm's Length Principle

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

   Author : Oskar Paladini Söderberg; [2019]
   Keywords : Transfer pricing; game theory; skatterätt; international taxation law; Arm s length principle; Law and Political Science;

   Abstract : The search of a business-optimal transfer price has been going on for decades. One interesting solution aimed to, by the use of game theory, bargaining theory and transfer pricing, create a quantitative solution to optimize the global profits of a multinational enterprise. READ MORE

6. 5. Compensating adjustments - An international perspective

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

   Author : Oskar Paladini Söderberg; [2018]
   Keywords : Skatterätt; finansrätt; fiscal law; transfer pricing; compensating adjustments; economic double taxation; Law and Political Science;

   Abstract : The purpose of this essay is to investigate if there exist any differences in the handling of compensating adjustments between Sweden and the UK and why these differences exist together with what consequences it may bring. Differences were identified, such as the fact that the UK only allows for compensating adjustments in an upward direction whilst Sweden accepts adjustments in both directions. READ MORE