Essays about: "Double Non-Taxation"

Showing result 1 - 5 of 16 essays containing the words Double Non-Taxation.

  1. 1. The incompatible Definitions of Intangibles between the OECD Guidelines and the U.S. Tax Cuts and Jobs Act from a Transfer Pricing Perspective.

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Julia Hochreiter; [2020]
    Keywords : Transfer pricing; definition of intangibles; goodwill; ongoing concern value; double taxation; double non-taxation; the OECD Transfer Pricing Guidelines; the U.S. Tax Cuts and Jobs Act.; Law and Political Science;

    Abstract : “What discrepancies arise from the incompatible definitions of intangibles for transfer pricing purposes according to the OECD Transfer Pricing Guidelines 2017 and the U.S. READ MORE

  2. 2. Allocation of Taxing Rights of Occupational Pension in Cross-Border Situations between an ETT- and EET- or TET-system : An Analysis between Sweden and Portugal

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Miranda Stenlund; [2020]
    Keywords : Private occupational pension; Cross-border situations; Allocation of taxing rights; Sweden; Portugal; Tax treaties; ETT-system; EET-system; TET-system;

    Abstract : The fact that pension consists of three cashflows that can be taxed at different points in time has resulted in a great divergence in how states treat the income of pension. Nonetheless, a majority of tax treaties allocate the exclusive taxing rights of private occupational pension to the residence state as advocated by the Organisation for Economic Co-operation and Development. READ MORE

  3. 3. A legal study into the EU’s approach towards exit taxation

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

    Author : Patricia Zakrzewska; [2020]
    Keywords : direct taxation; EU law; exit taxation; ATAD; anti-tax avoidance directive; Law and Political Science;

    Abstract : The purpose of the thesis is to analyse the EU’s and CJEU’s approach towards exit taxes by finding guidance on how the exit tax rules shall be made to be considered as compatible with the requirements of EU law. The EU law’s presumption of establishing an internal market without boundaries at the frontiers prohibits national measures which hinder, inter alia, the market access. READ MORE

  4. 4. Requirements for chain transactions in European VAT

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Sabrina Popp; [2019]
    Keywords : chain transaction; triangulation; European VAT; Law and Political Science;

    Abstract : Transactions where goods are successively supplied by several businesses and transported directly from the first supplier to the last customer are defined as chain transactions. There is currently no provision in the VAT Directive which generally defines and determines the VAT treatment of chain transactions. READ MORE

  5. 5. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Margret Agusta Sigurdardottir; [2016]
    Keywords : Tax; Taxation; Tax Law; Direct Taxation; Fundamental Freedoms; Double Taxation; Double Non-Taxation; Tax Avoidance; Aggressive Tax Planning; The Single Tax Principle; Single Taxation; Tax Treaty Law; GAAR; General Anti-Abuse Rule; Exemption Method; Credit Method; Dividend; Interest; Classification of Income; International Tax Regime; ECJ Case Law; Hybrid Mismatch Arrangements; Hybrid Financial Instruments; Parent-Subsidiary Directive; Base Erosion and Profit Shifting; BEPS; BEPS Action Plan 2; Anti-Hybrid Rules; Linking Rules; Correspondence Principle; Anti-Tax Avoidance Directive Proposal; Parent-Subsidiary Directive Amendments; Justification Grounds; EU Law; Law and Political Science;

    Abstract : The purpose of the thesis is to analyse the problems of hybrid mismatch arrangements within the EU and how single taxation, which requires income to be taxed once, not more or less, can be secured under EU law. After the amendments of the Parent-Subsidiary Directive (PSD), where an anti-hybrid rule was enacted, the legal environment for companies within the European Union changed. READ MORE