Essays about: "Tax Treaties"
Showing result 1 - 5 of 53 essays containing the words Tax Treaties.
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1. 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 institutionenAbstract : 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
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2. (E)merging value decreases in transferred assets - A study on tax aspects regarding post-merger value decreases in assets transferred upon merger
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The objective of this thesis has been twofold. Firstly, the purpose has been to examine how the outcomes for tax purposes, at the company level, differ depending on whether the assets transferred in a merger remain attributable to a P.E. READ MORE
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3. 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 institutionenAbstract : 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
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4. Do we need a new definition of Permanent Establishment for digital operations in Double Tax Treaties?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This master thesis investigates the need for a new Permanent Establishment (PE) definition for digital purposes in Double Tax Treaties (DTTs). In the core of the necessity to pursue the analysis of this, are the digital economic developments, and the challenges that they pose for international tax law, policymakers, countries, and businesses. READ MORE
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5. In What Way Does the Russian GAAR Comply With EU ATAD and BEPS Rules?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
