Essays about: "BEPS action 6"
Showing result 1 - 5 of 8 essays containing the words BEPS action 6.
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1. In What Way Does the Russian GAAR Comply With EU ATAD and BEPS Rules?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The issues of tackling aggressive tax planning are actual throughout the whole history of global market economy. Earlier this struggle was held by the states individually through imposing rules into their national legislation authorizing tax supervisory bodies to use new methods of control, establishing liability for tax evasion, and developing the approaches by judgements of the courts on relevant cases. READ MORE
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2. 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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3. The Authorized OECD Approach for the attribution of profits to Permanent Establishments in a Post-BEPS World : An analysis of the Authorized OECD Approach for the attribution of profits to Permanent Establishments which arise from commissionaire arrangements under BEPS Action 7
University essay from Uppsala universitet/Juridiska institutionenAbstract : The BEPS Project has led to unprecedented changes in international taxation rules. In this respect, the recent changes made to the definition of permanent establishment (PE) under BEPS Action 7 target aggressive tax structures used by multinationals enterprises (MNEs). READ MORE
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4. Is BEPS Action 6 “Preventing Treaty abuse” compatible with the EU Law concept of abuse?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of "granting treaty benefits in inappropriate circumstances". Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law. READ MORE
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5. BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty - Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The thesis provides an overview of the relationship between tax treaties and domestic law and issues that arise if a contracting state uses domestic anti-avoidance rules to prevent the improper use of a tax treaty. Improper use of a tax treaty is an issue addressed in the BEPS Action 6 report. READ MORE
