Essays about: "ATA Directive"

Found 3 essays containing the words ATA Directive.

  1. 1. To what extent the Anti-abuse measures concerning the interest limitation rule can be introduced into Member States without breaching EU law?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Pimfah Wirawan; [2017]
    Keywords : Interest limitation rules; Thin capitalisation; compatibility; fundamental freedoms; freedom of establishment; ATAD; ATA Directive; BEPS; Base erosion and profit shifting; BEPS action 4; Law and Political Science;

    Abstract : Under the BEPS action 4, the suggested best approach gives guidelines on how Member States can implement the interest limitation rules. The variation of rules and exceptions can facilitate the Member States to introduce the rules or at the same time can expand a gap of an implementation of domestic rules which is not harmonised. READ MORE

  2. 2. Limitations on interest deductions: does BEPS action 4 presume tax avoidance?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Latifa Omri; [2016]
    Keywords : Interest; limitations; deductions; BEPS; action 4; tax avoidance; presumption; international tax law; EU law; CJEU; thin capitalization; thin cap rules; anti-tax avoidance; fixed ratio rule; group ratio rule; the best practice approach; fundamental freedoms; case law.; Law and Political Science;

    Abstract : 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

  3. 3. Spurring Climate Change Action Beyond External Borders - A study of legal measures available to the EU to exert pressure on Canada to pursue climate change action in times of international institutional failure

    University essay from Lunds universitet/Juridiska institutionen

    Author : Lena Lundahl; [2014]
    Keywords : Canadian Climate Policy; EU Climate Policy; Climate Change Policy; Environmental Law; EU Law; EU-rätt; Miljörätt; Klimatpolitik; Law and Political Science;

    Abstract : Climate change is one of today’s major challenges; a challenge with significant consequences that will affect all countries in different ways if a way to combat global warming by stabilizing greenhouse gas emissions cannot be agreed on. A global problem calls for an international response; however, the international climate regime has failed to deliver adequate results. READ MORE