Essays about: "Allocation of taxing rights"

Showing result 1 - 5 of 12 essays containing the words Allocation of taxing rights.

  1. 1. The digital economy and its implications: does the OECD’s Pillar One Proposal challenge the principles of law within International and EU tax law?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Wihan Esterhuizen; [2023]
    Keywords : Tax; EU Law; OECD S Pillar One; principles of law; ability-to-pay; territoriality; state aid; transfer pricing; Arm s length principle; Law and Political Science;

    Abstract : Change is the only constant; yet, as we step into the brave new world of taxing the digital economy, it might seem like the need and development of principles and rules for adequate profit allocation has only begun. This thesis discusses the profit allocation rules under the Unified Approach of the OECD Pillar One Proposal Amount A in relation to three identified principles of law in international and European tax law. READ MORE

  2. 2. The Distribution Tax Regime Paradox - Compatibility of Estonian Tax Treatment of Non-Residents’ Capital Gains from Alienation of Immovable Property with European Law

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Henri Ahtiainen; [2022]
    Keywords : Taxation; EU Tax Law; Corporate income tax; witholding tax; capital gains; immovable property; real estate income; freedom of establishment; free movement of capital; distribution tax; principle of territoriality; balanced allocation of taxing rights; Law and Political Science;

    Abstract : The four fundamental freedoms granted to residents in the Community have become the pillars for fairness between economic operators and persons within the internal market. The aim of the freedoms is to prohibit any restriction or discrimination toward residents of another Member State and endorse equal treatment. READ MORE

  3. 3. Whether nexus rules under EU Commission proposal of Significant digital presence rules is compatible with separate provisions of international tax law

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Kostiantyn Nemchenko; [2021]
    Keywords : digital tax; nexus; tax law; international taxation; permanent establishment; Law and Political Science;

    Abstract : Growing digitalisation of the global economy is brining irreversible changes in business models and structure of economic relationships. External factors, such as pandemiс, only facilitate the process of remote participation in economic life and performing economic functions. READ MORE

  4. 4. Allocation of Taxing Rights of Occupational Pension in Cross-Border Situations between an ETT- and EET- or TET-system : An Analysis between Sweden and Portugal

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Miranda Stenlund; [2020]
    Keywords : Private occupational pension; Cross-border situations; Allocation of taxing rights; Sweden; Portugal; Tax treaties; ETT-system; EET-system; TET-system;

    Abstract : The fact that pension consists of three cashflows that can be taxed at different points in time has resulted in a great divergence in how states treat the income of pension. Nonetheless, a majority of tax treaties allocate the exclusive taxing rights of private occupational pension to the residence state as advocated by the Organisation for Economic Co-operation and Development. READ MORE

  5. 5. A legal study into the EU’s approach towards exit taxation

    University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

    Author : Patricia Zakrzewska; [2020]
    Keywords : direct taxation; EU law; exit taxation; ATAD; anti-tax avoidance directive; Law and Political Science;

    Abstract : The purpose of the thesis is to analyse the EU’s and CJEU’s approach towards exit taxes by finding guidance on how the exit tax rules shall be made to be considered as compatible with the requirements of EU law. The EU law’s presumption of establishing an internal market without boundaries at the frontiers prohibits national measures which hinder, inter alia, the market access. READ MORE