Essays about: "Double Taxation"

Showing result 1 - 5 of 73 essays containing the words Double Taxation.

  1. 1. Head in the sand when trust income is in sight? Analysis of double taxation of trust income originating from dividends in light of Articles 49 and 63 TFEU.

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Madara Olmane; [2023]
    Keywords : tax; Article 49 TFEU; Article 63 TFEU; trusts; fundamental freedoms; EU tax law; comparability; double taxation; trust income; dividends; freedom of establishment; free movement of capital; ECJ; flow-through dividends; coporate income tax; direct taxation; Law and Political Science;

    Abstract : This thesis challenges the treatment of trust income received in a country with no trusts in its legal system in light of freedom of establishment and free movement of capital. Can provisions of a Member State that has decided not to have trusts in its legal system make the transfer of shares or even the establishment of a trust elsewhere less favourable? This question, as the starting point of this thesis, managed to open a Pandora’s box of additional aspects and questions to consider, where each deserves a thesis on its own. READ MORE

  2. 2. Problems caused by unilateral measures while taxing the digital economy: Does the value creation approach suggested by OECD solve the problem?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Priyanka Kumari Prasad; [2023]
    Keywords : Unilateral measures; Equalisation levy; Diverted Profit Tax; Digital economy; Value creation approach; Juridical double taxation; OECD s Pillar One.; Law and Political Science;

    Abstract : This thesis examines the challenges arising from unilateral measures taken by both developing and developed countries to protect their taxing rights in the digital economy, leading to issues of double taxation. It focuses on India's equalisation levy and the UK's diverted profits tax (DPT) as examples of unilateral measures. READ MORE

  3. 3. Taxation of influencers: A double taxation or a non-double taxation issue?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Andrea Del Pilar Valbuena Bernal; [2022]
    Keywords : Taxation; Individual Income Tax; Influencers; International Income Tax; OECD Model Convention.; Law and Political Science;

    Abstract : Although states have begun to regulate influencer activities in areas such as advertising and consumer protection, that is not the case in tax law. This research analyses various Tax Authority’s guidelines on the matter and concludes that the rules already in place in most jurisdictions are applied to influencers’ activities. READ MORE

  4. 4. Transfer pricing adjustments derived from state aid cases - Are corresponding adjustments mandatory for EU Member States?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Ruby Michelle De Fátima Rojas Ixtacuy; [2022]
    Keywords : Corresponding adjustments; State Aid; Transfer pricing; Dispute Resolution Mechanisms; Arbitration; OCDE; double economic taxation; EU Member States; EU tax law; Tax Law; Law and Political Science;

    Abstract : When an EU MS executes a state aid recovery decision, specifically those cases regarding Advance Pricing Agreements (APAs), an economic double taxation issue and a potential TP dispute may arise, which could be generated by the need for the application of a corresponding adjustment. In any case, each jurisdiction has the discretion to determine if the application of a corresponding adjustment should be made. READ MORE

  5. 5. The Distribution Tax Regime Paradox - Compatibility of Estonian Tax Treatment of Non-Residents’ Capital Gains from Alienation of Immovable Property with European Law

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Henri Ahtiainen; [2022]
    Keywords : Taxation; EU Tax Law; Corporate income tax; witholding tax; capital gains; immovable property; real estate income; freedom of establishment; free movement of capital; distribution tax; principle of territoriality; balanced allocation of taxing rights; Law and Political Science;

    Abstract : The four fundamental freedoms granted to residents in the Community have become the pillars for fairness between economic operators and persons within the internal market. The aim of the freedoms is to prohibit any restriction or discrimination toward residents of another Member State and endorse equal treatment. READ MORE