Essays about: "international capital taxation"

Showing result 1 - 5 of 21 essays containing the words international capital taxation.

1. 1. Sweden as a tax haven - A research regarding if a tax haven can conduct high taxes and what other characteristics may be

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Hanna Rundh; [2022]
   Keywords : Tax; Tax law; Tax haven; Tax havens; OECD; EU; Tax Justice Network; Oxfam International; International tax law; European tax law; Europe; Sweden; Master; Law and Political Science;

   Abstract : This thesis is a research regarding if Sweden should be classified as a tax haven. To be able to classfie Sweden, four organisations have been researched, this is because there is no clear definition of the term tax haven. READ MORE

3. 2. 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

4. 3. 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

5. 4. Does the Substance over Form approach implemented as a result of the BEPS package reconciles the Permanent Establishment definition with the existence of economic allegiances?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Moisés Zúñiga Vargas; [2019]
   Keywords : Taxes; Permanent Establishment; economic allegiances; MLI; OECD; BEPS; Model Tax Convention; International taxation; Law and Political Science;

   Abstract : The Permanent Establishment (PE) concept plays a key role in the distribution of taxing rights between States by determining when the profits derived by an entity are taxable in a State other than the State of its residency. This concept, originally, evidenced the existence of sufficient economic allegiances between a non-resident entity and a State to justify taxation therein. READ MORE

6. 5. Interpretation and qualification of short-term employment in cross-border situation at Article 15(2)OECD MC

   University essay from Uppsala universitet/Juridiska institutionen

   Author : Shkumbin Asllani; [2017]
   Keywords : ;

   Abstract : The free movement of people and capital has enabled individuals and businesses to engage in cross-border transactions. Global economy and the competitiveness between international groups have acknowledged the necessity for a dynamic human workforce and openness of the labour market for mobility of workers within affiliated companies and different multinational enterprises. READ MORE