Essays about: "Double tax treaty"
Showing result 11 - 15 of 30 essays containing the words Double tax treaty.
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11. Whether the domestic anti-abuse legislation applies to deny the tax treaty benefits
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The question raised in this thesis – whether the domestic anti-abuse legislation applies to deny the tax treaty benefits – cannot be decided unambiguously. As controversial debate shows, it is rather difficult to elaborate the uniform international approach concerning this issue due to a number of arguments: the incorporation of double tax treaties into domestic law takes place differently in various countries; some countries do not have GAAR at all, while others have well developed doctrines or an express statutory provision, or even the combination of both; also, some states explicitly define the relationship between the tax treaties and the GAAR, whilst others do not. READ MORE
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12. Applicability of domestic anti-avoidance legislation in relation to tax treaty commitments - A case study placing Swedish law in an international doctrinal framework
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The present paper is an analysis of Swedish law, as expressed obiter dictum in the Supreme Administrative Court decision of HFD 2012 ref. 20, regarding applicability of Swedish general anti avoidance rules in relation to tax treaty commitments. The purpose of the paper is to put Swedish law, as envisaged by HFD 2012 ref. READ MORE
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13. The Beneficial Owner Concept in Civil Law Countries. Scandinavian Perspective.
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Free movement of goods, capital, workers and services have stimulated economic and social interaction between Member States of the European Union. At the same time international trade and globalization go far beyond the scope of the EU and have a tremendous impact on various countries in the world. READ MORE
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14. Bilateralism of tax treaties versus triangular cases: is there a conflict?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The paper examines the triangluar situations which occur because of the bilateral nature of double tax treaties and tries to find out whether a bilateral tax treaty is able to solve a situation between more than two states. The thesis discusses proposed solutions and assesses their application considering the bilateral nature of the treaties... READ MORE
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15. Per Aspera Ad Astra: Towards the International Fiscal Meaning of the Concept 'Beneficial Owner'
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The term ‘beneficial owner’ was first internationally introduced by the OECD in the Model Convention in 1977 and since that time it serves as one of the anti-abuse rules directly provided for in double tax treaties. The concept is critical for determining the eligibility of a person for the tax treaty benefits and for the allocation of taxing rights between two contracting states with regard to dividends, interest or royalties income. READ MORE
