Essays about: "International Income Tax"
Showing result 21 - 25 of 54 essays containing the words International Income Tax.
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21. The Territorial Limitation of the Swedish Wage Remuneration Rule for Closely Held Companies in light of EU- and Domestic Tax Law on Third Country Inbound Dividends
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The Swedish rules for closely held companies were enacted to combat income conversion abuse in limited liability companies where natural persons acted as both owners and employees. In the Swedish Income Tax Act, employment income is taxed according to a progressive rate while capital income is taxed according to a flat rate. READ MORE
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22. The Allocation of Residual Profits Deriving from Intangibles in a Transfer Pricing Context
University essay from Lunds universitet/Institutionen för handelsrättAbstract : After giving an introduction to the basics of transfer pricing with a focus on intangibles, this paper aims to establish the nature of residual profits and what needs to be considered when such profits are generated. It will become clear that residual profits are an economic concept rather than an element of tax law which is why, first, a connecting link needs to be found between these two disciplines. READ MORE
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23. Beneficial Ownership - a concept in identity crisis
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : The aim of this thesis is to analyze and determine the meaning of the term “Beneficial Owner”, in the model treaty of the OECD and therefore its meaning in bilateral negotiated treaties based on the model treaty. The term’s legacy and application is presented. READ MORE
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24. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
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25. Cross-border Loss Utilization Concerning the Tax Treatment of a Taxpayer’s Own Losses Attributable to a Permanent Establishment in Relation to the Territoriality Principle –From an International and EU law Perspective
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The European Commission has acknowledged the lack of cross-border utilization of losses. Companies operating internationally want to have a possibility to offset losses against taxable profits at the same time or as soon as possible after the losses incurred. READ MORE
