Essays about: "OECD MC"
Showing result 1 - 5 of 6 essays containing the words OECD MC.
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1. Secondary Transfer Pricing Adjustments: Interpretation Challenges within the EU and International Perspectives
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This master thesis elaborates on the issues of the secondary transfer pricing adjustments that are common yet not regulated in an efficient manner by the states. The core problem of the double taxation issues to follow is the unwillingness of the states to accept the administrative tax decisions of each other in such sensitive fields as transfer pricing. READ MORE
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2. Comparability Approaches of the CJEU Regards Dividends Received by Non-Resident CIVs: Is the Primary Law Sufficient or Not?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : For preventing economic double taxation and neutralization of choice between direct and indirect investments, states might grant domestic funds certain tax advantages while not extending it to non-residents, which possibly result in international double taxation. This issue arises mostly because of the different features of the investment funds. READ MORE
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3. Double Taxation Resulting from the ATAD: Is There A Relief?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Despite of the ambitious aim of the ATAD, the adverse effect of double taxation caused by the implementation of it is unsolved. It is therefore up to taxpayers to solve the conflict of norms by identifying the correct source of law for eliminating double taxation. READ MORE
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4. Interpretation and qualification of short-term employment in cross-border situation at Article 15(2)OECD MC
University essay from Uppsala universitet/Juridiska institutionenAbstract : The free movement of people and capital has enabled individuals and businesses to engage in cross-border transactions. Global economy and the competitiveness between international groups have acknowledged the necessity for a dynamic human workforce and openness of the labour market for mobility of workers within affiliated companies and different multinational enterprises. READ MORE
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5. A Comparative Approach to the Order of Priority of the Allocation of Taxing Rights over Business Profits in the OECD MC, the UN MC and the Andean Pact MC – The PE broadening. An Argentinean example.
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The current OECD´s PE threshold requires either a direct physical presence (fixed place of business) or an indirect presence through a legal representative (dependent agent). On the other hand, Model Conventions such as the UN MC, provide a wider PE threshold, including income generating activities which are not included under the OECD PE threshold. READ MORE
