Essays about: "Tax treaties"
Showing result 21 - 25 of 53 essays containing the words Tax treaties.
-
21. To What Extent Can Member States Have Anti-Avoidance Rules Limiting Interest Deduction? - an Analysis From a Swedish Perspective
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The Swedish Government introduced the Swedish interest deduction limitation rules as it was identified that the preferential tax treatment of debt in comparison to equity had been used by Multi-National Enterprises for tax planning purposes. The Swedish rules have, however, been under investigation of the European Commission, which, in a letter of formal notice to the Swedish Government, has stated that the rules are incompatible with the fundamental freedoms of EU law. READ MORE
-
22. Potential double tax treaty override of South African exit taxation law – how do tax treaties allocate the right to tax unrealized gains?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : South African income tax legislation makes provision for the levying of exit taxes or charges when individuals emigrate from or companies cease to be residents or become headquarter companies, or when controlled foreign companies (CFC) cease to be CFCs otherwise than by way of becoming residents. As indicated by the title the discourse followed in this paper entails the analysis of treaties to ascertain the connecting factors employed by the OECD Model treaty giving rise to signatories levying exit taxes. READ MORE
-
23. The free movement of capital and the freedom of establishment - a study regarding their interrelationship in the field of direct taxes
University essay from Lunds universitet/Juridiska institutionenAbstract : Since its inception, the EU has had a pivotal role in integrating the MS between each other and also has had an increasing influence on the national legislation of these states. Moreover, this process has naturally led to legal concerns on how to interpret the EU law and how to impose it to secure its integration for the future. READ MORE
-
24. Neutralisation of discrimination in direct taxation: the problem of applicability from the perspective of tax treaties and 'opt in' domestic clauses
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The thesis provides the analysis of the concept of neutralisation based on the existing case law of the CJEU, AGs' opinions and academic writings. It introduces the reader to the meaning, scope and the purpose of neutralisation. READ MORE
-
25. Assessment of "Anti-Hybrid" Approach to the Problem of Aggressive Tax Planning in the light of the European Commission’s proposal to amend Article 4(1)(a) of the Parent-Subsidiary Directive
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Hybrid mismatch arrangements, which exploit differences in the tax treatment of dividends and interest as well as differences in the classification of financial instruments between two or more countries, have been found to be a widely used tool in aggressive tax planning since multinational companies using hybrid financial instruments could benefit from the “double dip” phenomenon. This issue has been in the spotlight on different levels. READ MORE
