Essays about: "BEPS"

Showing result 1 - 5 of 40 essays containing the word BEPS.

  1. 1. The Compatability of the OECD MNA with EU Fundamental Freedoms and the Case Law on Abuse

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Danila Oborin; [2020]
    Keywords : Danish Beneficial Ownership Cases Tax Abuse Tax Evasion Modified Nexus Approach OECD Fundamental Freedoms Intellectual Property Preferential Regime Research and development; Law and Political Science;

    Abstract : The OECD Modified Nexus Approach (MNA) as found in BEPS Action 5 is the preferred method for implementing an IP regime. By linking IP-related expenditures to tax benefits, the approach redefined substance with the aim to prevent tax base erosion which could occur in lenient IP regimes. READ MORE

  2. 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 fakulteten

    Author : Hedvig Lärka; [2020]
    Keywords : corporate income taxation; cross-border taxation; jurisdiction; spatiality; legal geography; minimum taxation; unitary taxation; Global Anti Base Erosion; GLoBE; Pillar II; two pillar approach; tax transparency; transnational law; transnational taxation; international taxation; international law; OECD; BEPS; BEPS IF; Law and Political Science;

    Abstract : 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

  3. 3. In What Way Does the Russian GAAR Comply With EU ATAD and BEPS Rules?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Aleksei Shcherbakov; [2020]
    Keywords : Tax law; tax abuse; GAAR; ATAD; BEPS; CFC; EU law; Russian tax law; tax avoidance; Law and Political Science;

    Abstract : 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

  4. 4. 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 handelsrätt

    Author : Ola Nilsson; [2020]
    Keywords : DAC 6; Sweden s implementation; reportable cross-border arrangement; Law and Political Science;

    Abstract : 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

  5. 5. Does the Substance over Form approach implemented as a result of the BEPS package reconciles the Permanent Establishment definition with the existence of economic allegiances?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Moisés Zúñiga Vargas; [2019]
    Keywords : Taxes; Permanent Establishment; economic allegiances; MLI; OECD; BEPS; Model Tax Convention; International taxation; Law and Political Science;

    Abstract : The Permanent Establishment (PE) concept plays a key role in the distribution of taxing rights between States by determining when the profits derived by an entity are taxable in a State other than the State of its residency. This concept, originally, evidenced the existence of sufficient economic allegiances between a non-resident entity and a State to justify taxation therein. READ MORE