Essays about: "Anti-Abuse Rules"
Showing result 1 - 5 of 11 essays containing the words Anti-Abuse Rules.
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1. Targeted interest deduction limitation rules post-Lexel
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
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2. The General Anti-Avoidance Rules in International Tax Law and the Rule of Law – The Issue of Predictability and Taxpayers’ Rights
University essay from Uppsala universitet/Juridiska institutionenAbstract : This paper addresses a principle in international taxation that has long been a subject of controversy in many countries regarding the countering of abusive maneuverings in tax matters and had engendered debates amongst academic scholars concerning its predictibility. This anti-abuse principle, doctrine or clause in international tax matters had over the years received many names according to variant applied in each country. READ MORE
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3. In What Way Does the Russian GAAR Comply With EU ATAD and BEPS Rules?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The issues of tackling aggressive tax planning are actual throughout the whole history of global market economy. Earlier this struggle was held by the states individually through imposing rules into their national legislation authorizing tax supervisory bodies to use new methods of control, establishing liability for tax evasion, and developing the approaches by judgements of the courts on relevant cases. READ MORE
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4. Beneficial Ownership - a concept in identity crisis
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : The aim of this thesis is to analyze and determine the meaning of the term “Beneficial Owner”, in the model treaty of the OECD and therefore its meaning in bilateral negotiated treaties based on the model treaty. The term’s legacy and application is presented. READ MORE
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5. 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 handelsrättAbstract : 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
