Essays about: "double taxation"

Showing result 6 - 10 of 73 essays containing the words double taxation.

  1. 6. Secondary Transfer Pricing Adjustments: Interpretation Challenges within the EU and International Perspectives

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Andrii Falendysh; [2021]
    Keywords : tax law; transfer pricing; secondary transfer pricing adjustments; interpretation; PSD; parent-subsidiary directive; OECD MC; constructive dividends; constructive interest; constructive capital injection; secondary transaction; Law and Political Science;

    Abstract : This master thesis elaborates on the issues of the secondary transfer pricing adjustments that are common yet not regulated in an efficient manner by the states. The core problem of the double taxation issues to follow is the unwillingness of the states to accept the administrative tax decisions of each other in such sensitive fields as transfer pricing. READ MORE

  2. 7. Preventing Double Taxation Through Administrative Cooperation in VAT

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Emelie Madita Stetter; [2021]
    Keywords : Administrative Cooperation; VAT; Double Taxation; Resolution Mechanism; European Union; Internal Market; European VAT Administration; Tax Administration Dialogue; Law and Political Science;

    Abstract : This paper analyses the role of administrative cooperation in the European VAT system. It examines, to what extent Regulation 904/2010 obliges Member States to prevent double taxation issues in VAT and how the system of administrative cooperation could be amended to ensure a correct assessment of VAT taking into account other resolution mechanisms. READ MORE

  3. 8. The Main Forms of Business Vehicles In Argentina : The establishment of foreign company in Argentina Searching fiscal advantages

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Alejandro Arroyave Quintero; [2020]
    Keywords : ;

    Abstract : Analyses different business entities that exist in Argentina and show to persons/companies interesting in establishing a business the information necessary to choose the type of company that more advantages offered. The second, that is a specific objective that search identifies if exist fiscal advantages for establishing of business either through incentives for certain industrial sectors or a lower tax burden for transactions between companies or cross border payments, Also, will be mention in general way if Argentina is in line with the objectives that OECDE pursuit; to accomplish with preventing international double taxation and tax avoidance. READ MORE

  4. 9. The incompatible Definitions of Intangibles between the OECD Guidelines and the U.S. Tax Cuts and Jobs Act from a Transfer Pricing Perspective.

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Julia Hochreiter; [2020]
    Keywords : Transfer pricing; definition of intangibles; goodwill; ongoing concern value; double taxation; double non-taxation; the OECD Transfer Pricing Guidelines; the U.S. Tax Cuts and Jobs Act.; Law and Political Science;

    Abstract : “What discrepancies arise from the incompatible definitions of intangibles for transfer pricing purposes according to the OECD Transfer Pricing Guidelines 2017 and the U.S. READ MORE

  5. 10. Comparability Approaches of the CJEU Regards Dividends Received by Non-Resident CIVs: Is the Primary Law Sufficient or Not?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Serra Tor; [2020]
    Keywords : CIV-Investment Fund- Pension Fund-Withholding tax-Discrimination-TFEU Freedoms-Free Movement of Capital-Freedom of Establishment - OECD Model Convention 2017 - OECD s Commentary- UCITS Directive- AIFM Directive; Law and Political Science;

    Abstract : For preventing economic double taxation and neutralization of choice between direct and indirect investments, states might grant domestic funds certain tax advantages while not extending it to non-residents, which possibly result in international double taxation. This issue arises mostly because of the different features of the investment funds. READ MORE