Essays about: "Model Tax Convention"
Showing result 16 - 20 of 32 essays containing the words Model Tax Convention.
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16. Exit Taxation in the European Union, Is there really a problem?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Exit taxes represent an expression of state’s sovereignty by taxing value increases of assets, hidden reserves and any untaxed income that arose on its territory. These taxes are triggered before the state of emigration loses its power of taxation as a result of the transfer to the jurisdiction of another state when an individual or company changes residency. READ MORE
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17. Subject-to-tax clauses in Swedish double tax conventions concluded between 2004 - 2014
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The thesis deals whit double tax conventions and double non-taxation. The thesis aim is to analyse the Swedish double tax conventions concluded between 2004 and 2014 in order to find out whether the double tax conventions contain a subject-to tax clause. READ MORE
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18. 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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19. Permanent Establishment : With respect to attribution of income and the question of documentation of internal dealings
University essay from IHH, RättsvetenskapAbstract : In 2008 the Committee of Fiscal Affairs of OECD published its report on profit attributable to a permanent establishment. In 2010 article 7 of the OECD model tax convention was reformed, and the report was revised to better conform to the article. READ MORE
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20. 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