Essays about: "BEPS Action Plan"

Showing result 6 - 10 of 10 essays containing the words BEPS Action Plan.

1. 6. Transfer Pricing 2.0 - A case study on the role of transfer pricing on the integration of MNCs after increased tax equality

   University essay from Handelshögskolan i Stockholm/Institutionen för redovisning och finansiering

   Author : Dominik Maurer; Hampus Hellermark; [2017]
   Keywords : Transfer Pricing; BEPS Action Plan; Tax Equality; Paradox Theory; Integration;

   Abstract : This paper employs the dynamic equilibrium model of paradox theory to analyze the role of transfer pricing on the integration of MNCs after increased tax equality. Findings suggest that the role under examination evolved as a consequence of the OECD BEPS project, ultimately reinforcing vicious cycles. READ MORE

3. 7. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Margret Agusta Sigurdardottir; [2016]
   Keywords : Tax; Taxation; Tax Law; Direct Taxation; Fundamental Freedoms; Double Taxation; Double Non-Taxation; Tax Avoidance; Aggressive Tax Planning; The Single Tax Principle; Single Taxation; Tax Treaty Law; GAAR; General Anti-Abuse Rule; Exemption Method; Credit Method; Dividend; Interest; Classification of Income; International Tax Regime; ECJ Case Law; Hybrid Mismatch Arrangements; Hybrid Financial Instruments; Parent-Subsidiary Directive; Base Erosion and Profit Shifting; BEPS; BEPS Action Plan 2; Anti-Hybrid Rules; Linking Rules; Correspondence Principle; Anti-Tax Avoidance Directive Proposal; Parent-Subsidiary Directive Amendments; Justification Grounds; EU Law; Law and Political Science;

   Abstract : The purpose of the thesis is to analyse the problems of hybrid mismatch arrangements within the EU and how single taxation, which requires income to be taxed once, not more or less, can be secured under EU law. After the amendments of the Parent-Subsidiary Directive (PSD), where an anti-hybrid rule was enacted, the legal environment for companies within the European Union changed. READ MORE

4. 8. 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

5. 9. Country-by-Country Reporting: A study on how Swedish MNEs prepare for the new transfer pricing documentation requirement

   University essay from Handelshögskolan i Stockholm/Institutionen för redovisning och finansiering

   Author : Michaela Appelkvist; Olivia Jansson; [2016]
   Keywords : Country-by-Country Reporting; BEPS Action Plan; Transfer Pricing; Management Control Systems; Stakeholder Management;

   Abstract : This paper employs a hybrid methodological approach to study the impact of the steps taken to comply with the new transfer pricing documentation requirement, Country-by-Country (CbC) reporting, on the management control system (MCS) in a Swedish multinational enterprise (MNE). Based on the empirical case study findings and the results from the industry survey, we find that there are inconsistencies between how transfer pricing policies are developed according to the arm's length principle (ALP) and how the outcome from those policies are documented in the common CbC report model template developed by the OECD. READ MORE

6. 10. BEPS Action plan 13 in the light of confidentiality

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Filippa Håkansson; [2016]
   Keywords : BEPS; Action 13; CbC-reporting; OECD; Transfer Pricing; Transfer Pricing Documentation; Transparency; Law and Political Science;

   Abstract : OECD introduced 15 Action plans as part of the BEPS-project in 2014 in their work to combat base erosion and profit shifting (BEPS). Action plan 13 provides for a re-examined transfer pricing documentation and a new Country-by-country-reporting. The CbC-reporting is to be included in a three-tired approach including a master-file and a local-file. READ MORE