Essays about: "BEPS"

Showing result 1 - 5 of 36 essays containing the word BEPS.

  1. 1. 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

  2. 2. Can the Arm’s Length Principle in the OECD Transfer Pricing Guidelines Fulfil the Minimum Requirements of the Transaction Approach in the Controlled Foreign Company Rules under Anti-Tax Avoidance Directive?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Zhijie Qiu; [2019]
    Keywords : Arm s Length Principle; CFC Rules; ATAD; BEPS; Law and Political Science;

    Abstract : Generally, the ALP in TP regulations is widely applied in order to prevent price manipulation which will cause tax avoidance. And CFC regulations have usually been regarded as a “backstop” of TP regulations in terms of combating tax avoidance. READ MORE

  3. 3. Rethinking traditional source concepts in a digital economy

    University essay from Uppsala universitet/Juridiska institutionen

    Author : George Daniel Costache; [2019]
    Keywords : International; tax law; OECD; digital economy; BEPS; Action 1; EU law; digital PE; DST; tax law; source taxation;

    Abstract : 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

  4. 4. 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

  5. 5. 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 institutionen

    Author : Sevil Aliyeva; [2018]
    Keywords : The Authorized OECD Approach; commissionaire arrangements; attribution of profits to permanent establishments; BEPS; Action 7;

    Abstract : 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