Essays about: "Double Tax Treaty"

Showing result 1 - 5 of 30 essays containing the words Double Tax Treaty.

1. 1. Comparability Approaches of the CJEU Regards Dividends Received by Non-Resident CIVs: Is the Primary Law Sufficient or Not?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Serra Tor; [2020]
   Keywords : CIV-Investment Fund- Pension Fund-Withholding tax-Discrimination-TFEU Freedoms-Free Movement of Capital-Freedom of Establishment - OECD Model Convention 2017 - OECD s Commentary- UCITS Directive- AIFM Directive; Law and Political Science;

   Abstract : For preventing economic double taxation and neutralization of choice between direct and indirect investments, states might grant domestic funds certain tax advantages while not extending it to non-residents, which possibly result in international double taxation. This issue arises mostly because of the different features of the investment funds. READ MORE

3. 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

4. 3. Interpretation and qualification of short-term employment in cross-border situation at Article 15(2)OECD MC

   University essay from Uppsala universitet/Juridiska institutionen

   Author : Shkumbin Asllani; [2017]
   Keywords : ;

   Abstract : The free movement of people and capital has enabled individuals and businesses to engage in cross-border transactions. Global economy and the competitiveness between international groups have acknowledged the necessity for a dynamic human workforce and openness of the labour market for mobility of workers within affiliated companies and different multinational enterprises. READ MORE

5. 4. Reservations and Compatibility Clauses in the Multilateral Instrument: Overcoming New Interpretative Challenges

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Roberto Ramos Obando; [2017]
   Keywords : Tax; International Tax Law; Multilateral Instrument; Double Tax Treaty; BEPS; Reservations; Compatibility Clauses; Law and Political Science;

   Abstract : Adopted on November 2016, the Multilateral instrument for BEPS tax treaty measures (MLI) has come into play in the global tax treaty landscape. The MLI is a multilateral agreement that aims for a speedy implementation of the treaty measures agreed upon in the Base Erosion and Profit Shifting (BEPS) Project by allowing the modification of the bilateral double tax treaties (DTTs) without the need of individual negotiation of each treaty. READ MORE

6. 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