Essays about: "BEPS action 1"
Showing result 1 - 5 of 7 essays containing the words BEPS action 1.
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1. Rethinking traditional source concepts in a digital economy
University essay from Uppsala universitet/Juridiska institutionenAbstract : The purpose of this thesis is to provide meaningful understanding of the current state of business activities, which generates the need for implementing new taxing measures, analyse the challenges arising from this need, as well as their cause. Furthermore, the aforementioned challenges will be explained in the context of existing traditional taxing systems and proposed measures will be analysed. READ MORE
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2. The Base Erosion and Profit-Shifting Project, Action 7: A Critical Analysis of the Preparatory/Auxiliary Extension and the New Anti-Fragmentation Rule in the 2017 OECD Model Tax Convention
University essay from Uppsala universitet/Juridiska institutionenAbstract : The PE is a concept under scrutiny. Action 7 of the BEPS Action Plan has laid out a path to defend against artificial avoidance of PE status in light of BEPS concerns that can be associated with moderating business practices. Out of Action 7 has come an update to Art. READ MORE
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3. Profit-allocation based on value creation in the digital economy
University essay from Lunds universitet/Institutionen för handelsrättAbstract : With the proposed Directive by the European Commission to tax the digital economy more effective by introducing a digital permanent establishment, the question raises how to effectively tax it. Under the current profit-allocation principles, profits are allocated to the jurisdiction in which the significant people functions are situated. 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. How can the proposed changes to the OECD tax model convention in action 1 and action 7 counter the issue of an artificial avoidance of a PE status?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The purpose of this thesis is to clarify how, according to BEPS action 1 and action 7, can the amendments of the “specific activity exemptions” in article 5 paragraph 4 of the OECD Model Tax Convention on Income and Capital (the model convention) counter the issue of an artificial avoidance of a PE status. The main issues that are connected to the concept of a permanent establishment are artificial avoidance of the status of a permanent establishment, the use of transfer pricing rules in order to artificially allocate the profits of a permanent establishment to low tax states and finally that some enterprises that operate within the digital economy can avoid the status of a permanent establishment due to the lack of physical presence. READ MORE
