Essays about: "TAX TREATY"

Showing result 21 - 25 of 71 essays containing the words TAX TREATY.

1. 21. The Definition of a Permanent Establishment in the BEPS Era : An analysis of the introduction of commissionaire structures in Article 5(5) of the OECD Model Treaty

   University essay from Uppsala universitet/Juridiska institutionen

   Author : Camilla Berkesten Hägglund; [2017]
   Keywords : International tax law; Internationell skatterätt;

   Abstract : .... READ MORE

3. 22. 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

4. 23. Is BEPS Action 6 “Preventing Treaty abuse” compatible with the EU Law concept of abuse?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Amela Juka; [2016]
   Keywords : Treaty shopping; Treaty abuse; Anti-abuse rules; Double non-taxation; CJEU; LOB Clause; PPT rule; wholly artificial arrangements ; GAAR; BEPS; BEPS action 6; OECD; EU Fundamental Freedoms; EU law; Law and Political Science;

   Abstract : In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of "granting treaty benefits in inappropriate circumstances". Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law. READ MORE

5. 24. BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty - Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Johanna Fridh; [2016]
   Keywords : Tax treaty; tax treaty override; improper use of a tax treaty; anti-abuse rules; Limitation-on-benefits; Principal purpose test; General Anti-avoidance rules; BEPS; Action 6; agressive tax planning; Law and Political Science;

   Abstract : The thesis provides an overview of the relationship between tax treaties and domestic law and issues that arise if a contracting state uses domestic anti-avoidance rules to prevent the improper use of a tax treaty. Improper use of a tax treaty is an issue addressed in the BEPS Action 6 report. READ MORE

6. 25. Legal limits to promoting equity capital investments using fiscal measures - State aid perspective

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Jakub Olender; [2016]
   Keywords : State aid; Equity finance; Risk capital; Debt and equity taxation; Law and Political Science;

   Abstract : This contribution explores the area of tax law pertaining to treatment of debt and equity finance as well as devises recommendations for Member States of the European Union seeking to promote equity participation without the risk of infringing upon Community law provisions relating to State aid. The study begins with the presentation of the underlying issues pertaining to the choice between debt and equity finance as well as the notion of State aid as applicable in the field of fiscal measures. READ MORE