Essays about: "balanced allocation of taxing powers"
Found 3 essays containing the words balanced allocation of taxing powers.
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1. '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 institutionenAbstract : 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
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2. Cross-border Loss Utilization Concerning the Tax Treatment of a Taxpayer’s Own Losses Attributable to a Permanent Establishment in Relation to the Territoriality Principle –From an International and EU law Perspective
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The European Commission has acknowledged the lack of cross-border utilization of losses. Companies operating internationally want to have a possibility to offset losses against taxable profits at the same time or as soon as possible after the losses incurred. READ MORE
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3. Allocation of burden of proof that the arm's length principle was(not) breached under the TFEU Fundamental Freedoms
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The topic of this work is the correlation between the protection of tax base by transfer princing rules and EU Law requirements. In particular, the question that wil be dealt with in this paper is how the burdern of proof that the arm's length principle was (not) followed by the taxpayer should be allocated in EU Law Context? Firstly, the EU Law framwork that is relevant for transfer pricing rules of EU Member States will be analyzed. READ MORE
