Essays about: "OECD Model Convention"

Showing result 1 - 5 of 31 essays containing the words OECD Model Convention.

  1. 1. The “saving clause” : Examining the impact on the interpretation of distributive provisions in the OECD Model Tax Convention

    University essay from Stockholms universitet/Juridiska institutionen

    Author : Ebba Beskow; [2023]
    Keywords : Tax law; tax treaty; model tax convention; OECD; BEPS; saving clause; Skatterätt; skatteavtal; internationell skatterätt; OECD; modellavtal; skatteavtalsrätt; BEPS;

    Abstract : .... READ MORE

  2. 2. How Multipolarity and Globalization Have Changed the Nature of Tax Multilateralism : A Comparison of the OECD Model Tax Convention Negotiation with the Negotiation of Pillar One and Two

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Daniel Raddenbach; [2022]
    Keywords : tax; taxation; globalization; international relations; negotiation; Pillar One; Pillar Two; OECD; model tax treaty; multilateralism; cooperation; tax multilateralism; global minimum tax; digital services; bilateralism;

    Abstract : Can a multilateral negotiating process—that is, cooperation between many states in a single forum—successfully reform the network of bilateral tax treaties that currently makes up the bulk of international tax law? The BEPS Project aims to be the first major push for a multilateral tax process since the creation of the OECD’s Model Tax Convention in the 1960s. Through BEPS, the OECD and 130-plus countries are in final negotiations to implement Pillar One and Two, which will: (1) create a new taxing right for “market jurisdiction” countries on the profit of international companies that do business there without a physical presence; and (2) implement a top-up tax levied against companies that offshore profits from intangible assets in low-tax jurisdictions. READ MORE

  3. 3. Taxation of influencers: A double taxation or a non-double taxation issue?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Andrea Del Pilar Valbuena Bernal; [2022]
    Keywords : Taxation; Individual Income Tax; Influencers; International Income Tax; OECD Model Convention.; Law and Political Science;

    Abstract : Although states have begun to regulate influencer activities in areas such as advertising and consumer protection, that is not the case in tax law. This research analyses various Tax Authority’s guidelines on the matter and concludes that the rules already in place in most jurisdictions are applied to influencers’ activities. READ MORE

  4. 4. 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 handelsrätt

    Author : Serra Tor; [2020]
    Keywords : CIV-Investment Fund- Pension Fund-Withholding tax-Discrimination-TFEU Freedoms-Free Movement of Capital-Freedom of Establishment - OECD Model Convention 2017 - OECD s Commentary- UCITS Directive- AIFM Directive; Law and Political Science;

    Abstract : 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

  5. 5. A legal study into the EU’s approach towards exit taxation

    University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

    Author : Patricia Zakrzewska; [2020]
    Keywords : direct taxation; EU law; exit taxation; ATAD; anti-tax avoidance directive; Law and Political Science;

    Abstract : The purpose of the thesis is to analyse the EU’s and CJEU’s approach towards exit taxes by finding guidance on how the exit tax rules shall be made to be considered as compatible with the requirements of EU law. The EU law’s presumption of establishing an internal market without boundaries at the frontiers prohibits national measures which hinder, inter alia, the market access. READ MORE