Essays about: "wholly artificial arrangements"

Showing result 1 - 5 of 10 essays containing the words wholly artificial arrangements.

1. 1. Targeted interest deduction limitation rules post-Lexel

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Alexander Tale; [2022]
   Keywords : Tax; EU; European Union; Interest; Targeted interest deduction rules; CIT; Coporate income tax; BEPS; OECD; Pillar Two; DEBRA; ATAD; IRD; Lexel; SIAT; Thin Cap; Deduction; Sweden; Court of Justice; Business law; Business and Economics; Law and Political Science;

   Abstract : The need for targeted interest deduction rules is far from over. Most recently targeted interest deduction limitation rules have been presented in the proposal for a Directive implementing OECD Pillar Two in the EU, as well as in the proposal for a Directive on debt-equity bias reduction allowance. READ MORE

3. 2. Wholly Artificial Arrangements Under ATAD and EU Case Law.

   University essay from Uppsala universitet/Juridiska institutionen

   Author : Ndip-Achere Arrey Hansel; [2019]
   Keywords : ;

   Abstract : Since the coming into force of the EU Anti-Tax Avoidance Directive (ATAD), there has been a lot of questions as to the meaning of the concept of wholly artificial arrangements and how member states can enact legislation to combat abuse of rights and other fraudulent practices within the European Union. However, the concept of wholly artificial arrangements as enacted in articles 6 & 7 of the ATAD is not new. READ MORE

4. 3. Art. 4 ATAD : How the Interest Limitation Rule of the ATAD aligns with the Freedoms of the TFEU and National Constitutions

   University essay from Uppsala universitet/Juridiska institutionen

   Author : Caroline Meyer im Hagen; [2018]
   Keywords : ATAD; Interest Limitation;

   Abstract : This thesis addresses Art. 4 ATAD and looks at it from two different angles. Firstly, Art. 4 ATAD will be examined in the light of the TFEU freedoms. READ MORE

5. 4. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Margret Agusta Sigurdardottir; [2016]
   Keywords : Tax; Taxation; Tax Law; Direct Taxation; Fundamental Freedoms; Double Taxation; Double Non-Taxation; Tax Avoidance; Aggressive Tax Planning; The Single Tax Principle; Single Taxation; Tax Treaty Law; GAAR; General Anti-Abuse Rule; Exemption Method; Credit Method; Dividend; Interest; Classification of Income; International Tax Regime; ECJ Case Law; Hybrid Mismatch Arrangements; Hybrid Financial Instruments; Parent-Subsidiary Directive; Base Erosion and Profit Shifting; BEPS; BEPS Action Plan 2; Anti-Hybrid Rules; Linking Rules; Correspondence Principle; Anti-Tax Avoidance Directive Proposal; Parent-Subsidiary Directive Amendments; Justification Grounds; EU Law; Law and Political Science;

   Abstract : The purpose of the thesis is to analyse the problems of hybrid mismatch arrangements within the EU and how single taxation, which requires income to be taxed once, not more or less, can be secured under EU law. After the amendments of the Parent-Subsidiary Directive (PSD), where an anti-hybrid rule was enacted, the legal environment for companies within the European Union changed. READ MORE

6. 5. Is BEPS Action 6 “Preventing Treaty abuse” compatible with the EU Law concept of abuse?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Amela Juka; [2016]
   Keywords : Treaty shopping; Treaty abuse; Anti-abuse rules; Double non-taxation; CJEU; LOB Clause; PPT rule; wholly artificial arrangements ; GAAR; BEPS; BEPS action 6; OECD; EU Fundamental Freedoms; EU law; Law and Political Science;

   Abstract : In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of "granting treaty benefits in inappropriate circumstances". Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law. READ MORE