Essays about: "Juridical double taxation"

Showing result 1 - 5 of 8 essays containing the words Juridical double taxation.

  1. 1. 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

  2. 2. 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

  3. 3. Linking Rules Assessed Against European and National Legal Benchmarks - A Juridical Remedy to Mitigate Double Non-Taxation?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Oliver Frank; [2015]
    Keywords : Hybrid instruments; Linking Rules; BEPS; Action 2; OECD; Primary Rule; Secondary Rule; § 8b KStG; Law and Political Science;

    Abstract : 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

  4. 4. Problems of taxation of investment funds and underlying investors

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Andriy Byelka; [2013]
    Keywords : investment fund; CIV; Law and Political Science;

    Abstract : Different treatment of investment fund has a result of double taxation or non-taxation. The Court of Justice of the European Union has stated that in principle, juridical double taxation is not in itself unlawful, as there is no obligation for Member States to adapt their own tax systems to the different systems of tax of other Member States in order to eliminate the double taxation arising from the exercise in parallel of their fiscal sovereignty. READ MORE

  5. 5. The Beneficial Owner Concept in Civil Law Countries. Scandinavian Perspective.

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Alena Kryzhanouskaya; [2012]
    Keywords : beneficial ownership; tax treaty; treaty benefits; OECD; Model Tax Treaty; Law and Political Science;

    Abstract : 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