Essays about: "TAX TREATY"

Showing result 1 - 5 of 63 essays containing the words TAX TREATY.

  1. 1. 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

  2. 2. Allocation of Taxing Rights of Occupational Pension in Cross-Border Situations between an ETT- and EET- or TET-system : An Analysis between Sweden and Portugal

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Miranda Stenlund; [2020]
    Keywords : Private occupational pension; Cross-border situations; Allocation of taxing rights; Sweden; Portugal; Tax treaties; ETT-system; EET-system; TET-system;

    Abstract : The fact that pension consists of three cashflows that can be taxed at different points in time has resulted in a great divergence in how states treat the income of pension. Nonetheless, a majority of tax treaties allocate the exclusive taxing rights of private occupational pension to the residence state as advocated by the Organisation for Economic Co-operation and Development. READ MORE

  3. 3. The new Spanish digital service tax; will it pass the selectivity criterion on State aid grounds?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Dante Israel Mercado Trujillo; [2020]
    Keywords : Digital Service Tax; State Aid.; Law and Political Science;

    Abstract : The aim of this thesis is to present a comparability analysis between the tax on certain digital services approved by Spain; article 107 (1) of the Treaty on the Functioning of the European Union and the case law of the CJEU on state aid, to determine whether the application this tax gives competitive advantages to some companies over others.... READ MORE

  4. 4. The incompatability of art. 4 ATAD with freedom of establishment: Evidence from the Swedish implementation

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Richard Påhlsson; [2020]
    Keywords : Anti-Tax Avoidance Directive; ATAD; ATAD art 4; Interest limitation rules; Tax avoidance; Tax abuse; Transposition of EU directives.; Law and Political Science;

    Abstract : The Anti-Tax Avoidance Directive calls for a new chapter in the fight against tax avoidance and abuse in the European Union - as a minimum level of protection against tax avoidance practises is established. Member States have a certain degree of discretion when implementing the directive. READ MORE

  5. 5. In What Way Does the Russian GAAR Comply With EU ATAD and BEPS Rules?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Aleksei Shcherbakov; [2020]
    Keywords : Tax law; tax abuse; GAAR; ATAD; BEPS; CFC; EU law; Russian tax law; tax avoidance; Law and Political Science;

    Abstract : The issues of tackling aggressive tax planning are actual throughout the whole history of global market economy. Earlier this struggle was held by the states individually through imposing rules into their national legislation authorizing tax supervisory bodies to use new methods of control, establishing liability for tax evasion, and developing the approaches by judgements of the courts on relevant cases. READ MORE