Essays about: "BEPS action 4"
Showing result 1 - 5 of 8 essays containing the words BEPS action 4.
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1. Sweden’s implementation of DAC 6 – A proportionate measure to prevent tax avoidance and evasion in the form of aggressive tax planning
University essay from Lunds universitet/Institutionen för handelsrättAbstract : After the financial crisis in 2008, governments became more aware about how multinational enterprises exploited gaps in the architecture of the international tax system in the globalized world to artificially shift profits to places where there was little or no taxation. It is estimated that base erosion and profit shifting cost countries 100-240 billion USD in lost revenue annually which is equal to 4-10% of the global corporate income tax. READ MORE
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2. Thin Capitalization in the OECD, the EU and Sweden: policy responses, evaluation and alternatives.
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : 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
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3. 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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4. 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
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5. 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
