Essays about: "CFC rules"
Showing result 1 - 5 of 14 essays containing the words CFC rules.
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1. Taxing Digitalized Space: On the Roots and Reach of Claims to Global Tax Jurisdiction
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : 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
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2. 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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3. Double Taxation Resulting from the ATAD: Is There A Relief?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Despite of the ambitious aim of the ATAD, the adverse effect of double taxation caused by the implementation of it is unsolved. It is therefore up to taxpayers to solve the conflict of norms by identifying the correct source of law for eliminating double taxation. READ MORE
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4. Art. 7 and 8 ATAD - The CFC rules of the ATAD in the light of the freedoms of the TFEU
University essay from Uppsala universitet/Juridiska institutionenAbstract : .... READ MORE
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5. 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 handelsrättAbstract : 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
