Essays about: "tax convention"
Showing result 1 - 5 of 46 essays containing the words tax convention.
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1. The “saving clause” : Examining the impact on the interpretation of distributive provisions in the OECD Model Tax Convention
University essay from Stockholms universitet/Juridiska institutionenAbstract : .... READ MORE
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2. Does the solidarity contribution under the Council Regulation (EU) 2022/1854 on an emergency intervention to address high energy prices infringe the protection of property guaranteed by the European Convention of Human Rights?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This thesis discusses the legality of the solidarity contribution relative to Article 1 of Protocol 1 of the European Convention on Human Rights (ECHR). As such, this paper aims to provide an answer to the question “Does the solidarity contribution under the Council Regulation (EU) 2022/1854 on an emergency intervention to address high energy prices infringe Article 1 of Protocol 1 of the ECHR. READ MORE
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3. How Multipolarity and Globalization Have Changed the Nature of Tax Multilateralism : A Comparison of the OECD Model Tax Convention Negotiation with the Negotiation of Pillar One and Two
University essay from Uppsala universitet/Juridiska institutionenAbstract : Can a multilateral negotiating process—that is, cooperation between many states in a single forum—successfully reform the network of bilateral tax treaties that currently makes up the bulk of international tax law? The BEPS Project aims to be the first major push for a multilateral tax process since the creation of the OECD’s Model Tax Convention in the 1960s. Through BEPS, the OECD and 130-plus countries are in final negotiations to implement Pillar One and Two, which will: (1) create a new taxing right for “market jurisdiction” countries on the profit of international companies that do business there without a physical presence; and (2) implement a top-up tax levied against companies that offshore profits from intangible assets in low-tax jurisdictions. READ MORE
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4. Taxation of influencers: A double taxation or a non-double taxation issue?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
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5. 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 handelsrättAbstract : 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