Essays about: "non double taxation"

Showing result 1 - 5 of 28 essays containing the words non double taxation.

  1. 1. Taxation of influencers: A double taxation or a non-double taxation issue?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Andrea Del Pilar Valbuena Bernal; [2022]
    Keywords : Taxation; Individual Income Tax; Influencers; International Income Tax; OECD Model Convention.; Law and Political Science;

    Abstract : Although states have begun to regulate influencer activities in areas such as advertising and consumer protection, that is not the case in tax law. This research analyses various Tax Authority’s guidelines on the matter and concludes that the rules already in place in most jurisdictions are applied to influencers’ activities. READ MORE

  2. 2. The Distribution Tax Regime Paradox - Compatibility of Estonian Tax Treatment of Non-Residents’ Capital Gains from Alienation of Immovable Property with European Law

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Henri Ahtiainen; [2022]
    Keywords : Taxation; EU Tax Law; Corporate income tax; witholding tax; capital gains; immovable property; real estate income; freedom of establishment; free movement of capital; distribution tax; principle of territoriality; balanced allocation of taxing rights; Law and Political Science;

    Abstract : The four fundamental freedoms granted to residents in the Community have become the pillars for fairness between economic operators and persons within the internal market. The aim of the freedoms is to prohibit any restriction or discrimination toward residents of another Member State and endorse equal treatment. READ MORE

  3. 3. 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

  4. 4. 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. 5. Allocation of Taxing Rights of Occupational Pension in Cross-Border Situations between an ETT- and EET- or TET-system : An Analysis between Sweden and Portugal

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Miranda Stenlund; [2020]
    Keywords : Private occupational pension; Cross-border situations; Allocation of taxing rights; Sweden; Portugal; Tax treaties; ETT-system; EET-system; TET-system;

    Abstract : The fact that pension consists of three cashflows that can be taxed at different points in time has resulted in a great divergence in how states treat the income of pension. Nonetheless, a majority of tax treaties allocate the exclusive taxing rights of private occupational pension to the residence state as advocated by the Organisation for Economic Co-operation and Development. READ MORE