Essays about: "profit split method"
Showing result 1 - 5 of 10 essays containing the words profit split method.
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1. Income taxation at the right place at the right time - An analysis of the need for a virtual permanent establishment
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : In the last couple of years, taxation of the digital economy has become a subject that is on everybody’s mind. This has given rise to attempts from OECD and EU, amongst others, to solve this dilemma. READ MORE
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2. Profit-allocation based on value creation in the digital economy
University essay from Lunds universitet/Institutionen för handelsrättAbstract : With the proposed Directive by the European Commission to tax the digital economy more effective by introducing a digital permanent establishment, the question raises how to effectively tax it. Under the current profit-allocation principles, profits are allocated to the jurisdiction in which the significant people functions are situated. READ MORE
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3. 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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4. A Comparative Approach to the Order of Priority of the Allocation of Taxing Rights over Business Profits in the OECD MC, the UN MC and the Andean Pact MC – The PE broadening. An Argentinean example.
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The current OECD´s PE threshold requires either a direct physical presence (fixed place of business) or an indirect presence through a legal representative (dependent agent). On the other hand, Model Conventions such as the UN MC, provide a wider PE threshold, including income generating activities which are not included under the OECD PE threshold. READ MORE
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5. The Transfer Pricing Problem in a Service Firm : A Case Study on a Swedish Multinational Enterprise
University essay from Uppsala universitet/Företagsekonomiska institutionenAbstract : The purpose of this study is to answer the research question of how a service company (ServiceCo) could achieve a transfer price of its services. This is of particular interest, due to the growth of service firms that have rapidly increased and surpassed the manufacturing firms, as well as the dominant logic shifting towards services. READ MORE
