Essays about: "Double Non-Taxation"
Showing result 6 - 10 of 16 essays containing the words Double Non-Taxation.
-
6. Neutralizing the Effects of Hybrid Mismatch Arrangements on a EU Level - To what extent can Member States be obliged to align their tax systems to each other?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Due to the on-going discussion regarding the OECD/G20 BEPS project and its particular actions it is an important task for the EU legislator to establish a reasonable and functional legal framework in order to ensure a certain degree of uniformity of Anti-BEPS measures within the European Union. In doing so, the protagonists must respect the boundaries set to domestic law as well as to measures of secondary legislation by primary EU law. READ MORE
-
7. Is BEPS Action 6 “Preventing Treaty abuse” compatible with the EU Law concept of abuse?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of "granting treaty benefits in inappropriate circumstances". Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law. READ MORE
-
8. Linking Rules Assessed Against European and National Legal Benchmarks - A Juridical Remedy to Mitigate Double Non-Taxation?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This thesis provides a comprehensive analysis of linking rules, which were adapted as one of the alleged remedies against base erosion by the EU and the OECD. A number of issues emerge in connection with those recommended rules. This thesis will thus assess compliance of those rules against domestic and European legal benchmarks. READ MORE
-
9. Subject-to-tax clauses in Swedish double tax conventions concluded between 2004 - 2014
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The thesis deals whit double tax conventions and double non-taxation. The thesis aim is to analyse the Swedish double tax conventions concluded between 2004 and 2014 in order to find out whether the double tax conventions contain a subject-to tax clause. READ MORE
-
10. PE Threshold for Business Profits in E-Commerce Context-To what extent does the present Permanent Establishment threshold influence the taxation of Electronic Commerce cross-border transactions?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Issues related to attribution of profits already exist in the traditional economic framework and are of a different nature, however these issues seem to become more bothersome in transactions conducted in e-commerce context, with an electronic economy. The matter is similar to the traditional economic problems in regard to transfer pricing adjustments; however these issues are much more complex due to the e-commerce nature, especially when considering the fact that multinational enterprises may gather data from different jurisdictions, and for different purposes, which makes the tracing of the source of the data highly complex. READ MORE