Essays about: "ACT Group Litigation case"

Found 2 essays containing the words ACT Group Litigation case.

  1. 1. The Territorial Limitation of the Swedish Wage Remuneration Rule for Closely Held Companies in light of EU- and Domestic Tax Law on Third Country Inbound Dividends

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Joel Dahl; [2017]
    Keywords : rå 2007 ref 59; rå 2000 ref 38; rå 2000 ref 47; qualified shares; market access; purpose approach; definite influence; rå 2007; rå 2000; skatteverket v a and b; eea; eu; association agreements; dividend; third countries; article 49; article 63; free movement of capital; freedom of establishment; world wide taxation; european and international taxation; tax law; tax; sweden; swedish income tax; capital export neutrality; FII group litigation; Kronos; Baars; SECIL; inbound dividends; inbound dividend; closely held companies; territorial limitation; wage remuneration; Law and Political Science;

    Abstract : The Swedish rules for closely held companies were enacted to combat income conversion abuse in limited liability companies where natural persons acted as both owners and employees. In the Swedish Income Tax Act, employment income is taxed according to a progressive rate while capital income is taxed according to a flat rate. READ MORE

  3. 2. Does the LOB clause in BEPS Action 6 violate the principle of MFN treatment in EU law?

    University essay from Lunds universitet/Juridiska institutionen

    Author : Sascha Åkerman; [2016]
    Keywords : tax law; EU law; BEPS; tax planning; tax avoidance; aggressive tax planning; LOB clause; LOB rule; limitation on benefit; MFN treatment; MFN principle; principle of MFN treatment; ACT Group Litigation case; Sopora case; D case; Orange European Smallcap Fund case; WTO; GATT; Law and Political Science;

    Abstract : OECD delivered on October 5th 2015 the BEPS final package consisting of 15 actions intending to address the issues of base erosion and profit shifting. The aim of Action 6 is to prevent treaty abuse, in particular treaty shopping. READ MORE