Essays about: "BEPS action 4"

Showing result 1 - 5 of 7 essays containing the words BEPS action 4.

  1. 1. Thin Capitalization in the OECD, the EU and Sweden: policy responses, evaluation and alternatives.

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

    Author : Sotirios Apostolou; [2018]
    Keywords : Tax law; OECD; BEPS; BEPS Action 4; EU; ATAD; Thin Capitalization; debt bias; tax planning; tax shield; interest deduction; interest deduction limitation; interest deduction limitation rule; EBITDA; CBIT; ACE; ACC; COCA; AGI; Law and Political Science;

    Abstract : The issue of thin capitalization has risen in importance in recent years, to the point that it warranted international action. That action came in the form of Action 4 of the OECD BEPS Project, of Article 4 of the EU ATAD and of the new interest deduction limitation rules in the national Swedish legislation. READ MORE

  2. 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 institutionen

    Author : John Gillespie; [2018]
    Keywords : ;

    Abstract : 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

  3. 3. 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 handelsrätt

    Author : Pimfah Wirawan; [2017]
    Keywords : Interest limitation rules; Thin capitalisation; compatibility; fundamental freedoms; freedom of establishment; ATAD; ATA Directive; BEPS; Base erosion and profit shifting; BEPS action 4; Law and Political Science;

    Abstract : 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

  4. 4. 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

  5. 5. 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