Essays about: "BEPS IF"
Showing result 1 - 5 of 10 essays containing the words BEPS IF.
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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. Taxing Digitalized Space: On the Roots and Reach of Claims to Global Tax Jurisdiction
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : Facing a digitalized global economy, where almost half of multinational corporate profits go untaxed, we find ourselves on the verge of tax revolution. With its two-pillar solution, the OECD seeks to lay the first building blocks of a new system for cross-border corporate income taxation. READ MORE
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3. Hard to value intangibles from a Swedish perspective
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The purpose of this thesis is to study the work of the OECD presented in the Final BEPS-Report under Action 8 concerning hard to value intangibles in a Swedish context. Further, the OECD Model Tax Convention and its Commentaries are discussed in terms of their validity as a source of law in a Swedish perspective, or if there is a requirement now or after the implementation of Action 8 for changes to the Inkomstskattelagen, and particular the Korrigeringsregeln. READ MORE
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4. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
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5. Limitations on interest deductions: does BEPS action 4 presume tax avoidance?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
