Essays about: "double taxation"

Showing result 21 - 25 of 73 essays containing the words double taxation.

  1. 21. The interplay between free movement provisions of persons and double taxation of individuals in the European Union

    University essay from Örebro universitet/Institutionen för juridik, psykologi och socialt arbete

    Author : Adelisa Omerovic; [2017]
    Keywords : ;

    Abstract : .... READ MORE

  3. 22. Hard to value intangibles from a Swedish perspective

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Håkan Vahlsten; [2017]
    Keywords : BEPS Action 8-10; Transfer Pricing; Arm s length principle; Arm s length distance; Inkomstskattelagen; Korrigeringsregeln; Intangibles; Hard To Value Intangibles; HTVI; Law and Political Science;

    Abstract : The purpose of this thesis is to study the work of the OECD presented in the Final BEPS-Report under Action 8 concerning hard to value intangibles in a Swedish context. Further, the OECD Model Tax Convention and its Commentaries are discussed in terms of their validity as a source of law in a Swedish perspective, or if there is a requirement now or after the implementation of Action 8 for changes to the Inkomstskattelagen, and particular the Korrigeringsregeln. READ MORE

  4. 23. Reservations and Compatibility Clauses in the Multilateral Instrument: Overcoming New Interpretative Challenges

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Roberto Ramos Obando; [2017]
    Keywords : Tax; International Tax Law; Multilateral Instrument; Double Tax Treaty; BEPS; Reservations; Compatibility Clauses; Law and Political Science;

    Abstract : Adopted on November 2016, the Multilateral instrument for BEPS tax treaty measures (MLI) has come into play in the global tax treaty landscape. The MLI is a multilateral agreement that aims for a speedy implementation of the treaty measures agreed upon in the Base Erosion and Profit Shifting (BEPS) Project by allowing the modification of the bilateral double tax treaties (DTTs) without the need of individual negotiation of each treaty. READ MORE

  5. 24. Financing Costs and Overhead Deduction in Cross-Border Transaction - A Requirement of EU Law?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Inken Gärtner; [2016]
    Keywords : Source Taxation; Withholding Tax; Interest Taxation; Cost Deduction; Overhead Deduction; Law and Political Science;

    Abstract : This Master thesis explores the EU law requirements for the taxation of the provision of cross-border services by the source state. As often the field of direct taxation, this is a delicate area where tension exists between the tax sovereignty of the Member States and the EU’s aim of the realization of an internal market. READ MORE

  6. 25. 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