Essays about: "BEPS"

Showing result 6 - 10 of 36 essays containing the word BEPS.

  1. 6. 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

  2. 7. Tangible Intangibles in the United States’ Tax Cuts and Jobs Act : How Mixed Definitions of “Intangible” Lead to Mixed Results in the United States’ Efforts to Close Tax Loopholes, Move to a Territorial Tax System, and Reduce Base Erosion and Profit Shifting Abuses

    University essay from Uppsala universitet/Juridiska institutionen

    Author : James Summers; [2018]
    Keywords : tax; law; international tax law; intangible; tangible; property; income; definition; territorial tax system; worldwide tax system; OECD; WTO; United States; TCJA;

    Abstract : The United States’ Tax Cuts and Jobs Act of 2017 (TCJA) changed a 30-year-old definition of the term “intangible property” and added assessment requirements for two different types of “intangible income”, both of which deviate from the newly changed general definition of “intangible” and most common understandings of the meaning of the word.  While it may appear unlikely that a change in meaning of a single word in a large tax code could have a drastic effect on international taxation, the differing definitions of “intangible” create far-reaching tangible consequences. READ MORE

  3. 8. General Anti-Avoidance Rules and Legal Certainty in Sweden, USA and China – A taxation determined by legal culture?

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

    Author : Markus Nyberg Andersson; [2018]
    Keywords : Tax Avoidance; Legal Certainty; GAAR; Sweden; United States; USA; U.S.; China; General Anti-Avoidance Rules; Tax law; skatterätt; internationell skatterätt; international tax law; ATAD; BEPS Project; Chinese GAAR; SAAR; OECD; Swedish GAAR; U.S. GAAR; People s Republic of China; Law and Political Science;

    Abstract : The occurrence of taxpayers implementing arrangements without commercial purpose to avoid tax laws and reduce their taxation, id est tax avoidance, is counteracted in most legal systems with different methods. Most jurisdictions have implemented not only Specific Anti-Avoidance Rules ("SAARs"), but also General Anti Avoidance Rules ("GAARs") to counteract tax avoidance. READ MORE

  4. 9. Aggressive Measures for Aggressive Schemes: Human Rights Perspectives

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Danilo Penetrante Ventajar; [2018]
    Keywords : Taxation; Human Rights; BEPS; BEPS Action Plan 12; Mandatory Disclosure Rules; Aggressive Tax Planning; Abusive Tax Planning; Tax Avoidance; Fairness; ECHR; EU Charter of Fundamental Rights; Directive on Administrative Cooperation; DAC; DAC6; right to property; right to privacy; right to fair trial; LPP; Law and Political Science;

    Abstract : The focus of this thesis is the EU Directive on mandatory disclosure rules on intermediaries that make available potentially aggressive cross-border tax arrangements. Its avowed purpose is to arrest base erosion and to address fairness in taxation. READ MORE

  5. 10. Profit-allocation based on value creation in the digital economy

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Tim Theunis; [2018]
    Keywords : Digital economy; value creation; tax; taxation; profit-allocation; permanent establishment; digital permanent establishment; virtual permanent establishment; formulary apportionment; arm s length principle; BEPS Action 1; BEPS Action 7; digitalization; digitalisation; European Commission; Directive; attribution of profits; value drivers; user jurisdiction; data; profit split method; transfer pricing; Law and Political Science;

    Abstract : With the proposed Directive by the European Commission to tax the digital economy more effective by introducing a digital permanent establishment, the question raises how to effectively tax it. Under the current profit-allocation principles, profits are allocated to the jurisdiction in which the significant people functions are situated. READ MORE