Essays about: "base erosion"
Showing result 1 - 5 of 39 essays containing the words base erosion.
-
1. Compatibility of Income Inclusion rule with EU Law. : GLoBE IIR and EU Law.
University essay from Uppsala universitet/Juridiska institutionenAbstract : In October 2021, 137 countries and jurisdictions agreed on a common approach towards a global minimum tax of 15% on the profits of large multinational companies that is referred to as the Pillar Two Model Rules, ‘Anti Global Base Erosion’, or ‘GloBE’ Rules. This political agreement implies that member countries who wish to implement such a tax regime have to streamline its design by modelling it after the so called Global Anti-Base Erosion Proposal (‘GloBE’) that the IF has developed as ‘Pillar 2’ of its work program on tax challenges arising from the digitalization of the economy. READ MORE
-
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 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
-
3. Targeted interest deduction limitation rules post-Lexel
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The need for targeted interest deduction rules is far from over. Most recently targeted interest deduction limitation rules have been presented in the proposal for a Directive implementing OECD Pillar Two in the EU, as well as in the proposal for a Directive on debt-equity bias reduction allowance. READ MORE
-
4. Tax Avoidance, Aggressive Tax Planning, and the United States’ Tax Cuts and Jobs Act of 2017 : An Investigation into Anti-Base Erosion and Anti-Profit Shifting Strategies
University essay from Uppsala universitet/Juridiska institutionenAbstract : .... READ MORE
-
5. How Multipolarity and Globalization Have Changed the Nature of Tax Multilateralism : A Comparison of the OECD Model Tax Convention Negotiation with the Negotiation of Pillar One and Two
University essay from Uppsala universitet/Juridiska institutionenAbstract : Can a multilateral negotiating process—that is, cooperation between many states in a single forum—successfully reform the network of bilateral tax treaties that currently makes up the bulk of international tax law? The BEPS Project aims to be the first major push for a multilateral tax process since the creation of the OECD’s Model Tax Convention in the 1960s. Through BEPS, the OECD and 130-plus countries are in final negotiations to implement Pillar One and Two, which will: (1) create a new taxing right for “market jurisdiction” countries on the profit of international companies that do business there without a physical presence; and (2) implement a top-up tax levied against companies that offshore profits from intangible assets in low-tax jurisdictions. READ MORE
