Essays about: "group ratio rule"
Found 3 essays containing the words group ratio rule.
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1. Limitations on interest deductions: does BEPS action 4 presume tax avoidance?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Debt and equity are in most countries treated differently for taxing purposes. The asymmetry between the financing forms are being taken advantage of by MNEs, allowing them to plan their cross-border activities in a way that lowers the taxable burden for the whole group. READ MORE
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2. Policy drivers behind the forest utilisation in Poland, Lithuania and Latvia
University essay from SLU/Southern Swedish Forest Research CentreAbstract : This work is a part of international research that was carried out in Latvia, Lithuania and Poland, in order to investigate policy drivers behind the harvesting level in these countries. This thesis was focused on Lithuania. READ MORE
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3. Thin Capitalisation : A comparison of the application of article 9.1of the OECD model tax convention and the Swedish adjustment rule to thin capitalisation
University essay from IHH, RättsvetenskapAbstract : This thesis answers the question “How does the application of the Swedish adjustment rule correspond to the OECD point of view regarding intragroup loans to thinly capitalised companies?” The question is answered by using the traditional legal method and by examining the way the adjustment rule is applied by the Supreme Administrative Court, the Swedish approach when using the arm’s length principle in Swedish law is then compared to the approach recommended by the OECD. From a tax point of view intragroup prices on commodities and services are of vital importance for multinational enterprises, since these prices in the end affects the total corporate taxation. READ MORE