Essays about: "artificial avoidance"

Showing result 1 - 5 of 20 essays containing the words artificial avoidance.

  1. 1. Dependent Agents after BEPS : Especially with regard to commissionaire arrangements

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Gustav Einar; [2017]
    Keywords : ;

    Abstract : The OECD estimates that every year between 100 and 240 billion US dollars of tax revenue is lost due to domestic tax base erosion and profit shifting resulting from the business practices used by multinational enterprises. In 2013, the BEPS Action Plan, encompassing 15 different actions, was sanctioned in response. READ MORE

  2. 2. Using Event Data Recorder (EDR) data to perform What-if simulations for safety benefit analysis by reconstructing real traffic kinematics and driver behaviors

    University essay from Chalmers tekniska högskola/Institutionen för tillämpad mekanik

    Author : Rakshith Mukunda Rao; [2017]
    Keywords : Event Data Recorder EDR ; Driver glance behaviour; Counterfactual simulations; Rear end collision; Safety benefit; Active Safety System evaluation;

    Abstract : As the focus of traffic safety stakeholders shifts from passive safety to active safety, the need to predictively evaluate safety systems in addition to identifying driver behaviour in critical situations has come to the forefront. Availability of a wide variety of data has opened up new research possibilities; real world crash data is increasingly accessible through Event Data Recorder (EDR) data, although little information is available about the context of the crash. READ MORE

  3. 3. Is BEPS Action 6 “Preventing Treaty abuse” compatible with the EU Law concept of abuse?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Amela Juka; [2016]
    Keywords : Treaty shopping; Treaty abuse; Anti-abuse rules; Double non-taxation; CJEU; LOB Clause; PPT rule; wholly artificial arrangements ; GAAR; BEPS; BEPS action 6; OECD; EU Fundamental Freedoms; EU law; Law and Political Science;

    Abstract : In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of "granting treaty benefits in inappropriate circumstances". Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law. READ MORE

  4. 4. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Margret Agusta Sigurdardottir; [2016]
    Keywords : Tax; Taxation; Tax Law; Direct Taxation; Fundamental Freedoms; Double Taxation; Double Non-Taxation; Tax Avoidance; Aggressive Tax Planning; The Single Tax Principle; Single Taxation; Tax Treaty Law; GAAR; General Anti-Abuse Rule; Exemption Method; Credit Method; Dividend; Interest; Classification of Income; International Tax Regime; ECJ Case Law; Hybrid Mismatch Arrangements; Hybrid Financial Instruments; Parent-Subsidiary Directive; Base Erosion and Profit Shifting; BEPS; BEPS Action Plan 2; Anti-Hybrid Rules; Linking Rules; Correspondence Principle; Anti-Tax Avoidance Directive Proposal; Parent-Subsidiary Directive Amendments; Justification Grounds; EU Law; Law and Political Science;

    Abstract : The purpose of the thesis is to analyse the problems of hybrid mismatch arrangements within the EU and how single taxation, which requires income to be taxed once, not more or less, can be secured under EU law. After the amendments of the Parent-Subsidiary Directive (PSD), where an anti-hybrid rule was enacted, the legal environment for companies within the European Union changed. READ MORE

  5. 5. How can the proposed changes to the OECD tax model convention in action 1 and action 7 counter the issue of an artificial avoidance of a PE status?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Maria Wettersten; [2016]
    Keywords : Permanent establishment; BEPS action 1; BEPS action 7; artificial avoidance; Law and Political Science;

    Abstract : The purpose of this thesis is to clarify how, according to BEPS action 1 and action 7, can the amendments of the “specific activity exemptions” in article 5 paragraph 4 of the OECD Model Tax Convention on Income and Capital (the model convention) counter the issue of an artificial avoidance of a PE status. The main issues that are connected to the concept of a permanent establishment are artificial avoidance of the status of a permanent establishment, the use of transfer pricing rules in order to artificially allocate the profits of a permanent establishment to low tax states and finally that some enterprises that operate within the digital economy can avoid the status of a permanent establishment due to the lack of physical presence. READ MORE