Essays about: "Aggressive Tax Planning"
Showing result 16 - 18 of 18 essays containing the words Aggressive Tax Planning.
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16. Does the LOB clause in BEPS Action 6 violate the principle of MFN treatment in EU law?
University essay from Lunds universitet/Juridiska institutionenAbstract : 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
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17. The Principal Purpose Test under BEPS Action 6: Does the OECD Proposal Fit the EU Legal Framework?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : On October 5, 2015, the Organization for Economic Cooperation and Development published the final package of 15 actions under the BEPS initiative. This package, in particular, includes the Final Report on Action 6 – ‘Preventing the granting of treaty benefits in inappropriate circumstances’, which is intended to provide countries with the ‘minimum level of protection against treaty abuse’. READ MORE
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18. Assessment of "Anti-Hybrid" Approach to the Problem of Aggressive Tax Planning in the light of the European Commission’s proposal to amend Article 4(1)(a) of the Parent-Subsidiary Directive
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Hybrid mismatch arrangements, which exploit differences in the tax treatment of dividends and interest as well as differences in the classification of financial instruments between two or more countries, have been found to be a widely used tool in aggressive tax planning since multinational companies using hybrid financial instruments could benefit from the “double dip” phenomenon. This issue has been in the spotlight on different levels. READ MORE
