Essays about: "TAX TREATY"

Showing result 6 - 10 of 71 essays containing the words TAX TREATY.

1. 6. The General Anti-Avoidance Rules in International Tax Law and the Rule of Law – The Issue of Predictability and Taxpayers’ Rights

   University essay from Uppsala universitet/Juridiska institutionen

   Author : Rufus Bloh Senyon; [2022]
   Keywords : GAAR; OECD Treaty GAAR; EU GAAR; Taxpayers Rights and Fuller s Morality of Law Principles;

   Abstract : This paper addresses a principle in international taxation that has long been a subject of controversy in many countries regarding the countering of abusive maneuverings in tax matters and had engendered debates amongst academic scholars concerning its predictibility. This anti-abuse principle, doctrine or clause in international tax matters had over the years received many names according to variant applied in each country. READ MORE

3. 7. Justifying Mobility Hindrance in the Name of Public Health and Its Tax Implication in the European Union

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Novanti Nayasaputri Suhana; [2021]
   Keywords : freedom of movement of person; principle of proportionality; tax implication; Law and Political Science;

   Abstract : This master thesis seeks to find an answer whether the restriction on freedom of movement of person can be justified on the ground of public health and also explaining what tax implication could happen for taxpayers in the context of pandemic relating to tax treaty interpretation. The right of freedom of movement of persons will be examined from the perspective of EU law. READ MORE

4. 8. Taxing the Digital Economy in Developing Countries - A Legal Comparison Between OECD’s Pillar One and UN’s Article 12B

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

   Author : Elma Hadzovic; [2021]
   Keywords : skatterätt; international tax law; OECD; Pillar One; UN; Article 12B; Law and Political Science;

   Abstract : Beskattning av den digitala ekonomin har varit en av de mest centrala delarna i den internationella skattekontexten under det senaste decenniet. Digitaliseringen har gett upphov till nya affärsmodeller som har lett till ett ökat tryck på det internationella skattesystemet som inrättades på 1920-talet. READ MORE

5. 9. 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

6. 10. 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