Essays about: "Thin capitalisation"
Found 5 essays containing the words Thin capitalisation.
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1. To what extent the Anti-abuse measures concerning the interest limitation rule can be introduced into Member States without breaching EU law?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Under the BEPS action 4, the suggested best approach gives guidelines on how Member States can implement the interest limitation rules. The variation of rules and exceptions can facilitate the Member States to introduce the rules or at the same time can expand a gap of an implementation of domestic rules which is not harmonised. READ MORE
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2. Thin capitalisation- compatible with EC law?
University essay from Lunds universitet/Juridiska institutionenAbstract : Thin capitalization means an abnormally high debt-to-equity ratio of a corporation, in a situation where the debt finance comes from a foreign affiliated contributor of capital. The contributor of debt capital is often simultaneously a direct shareholder. READ MORE
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3. Tax as a key driver in motivating company investments: The case of debt push down
University essay from Handelshögskolan i Stockholm/Institutionen för redovisning och finansieringAbstract : The aim of this thesis is to examine the legal situation with regard to debt push down structures in Sweden. Debt push down structures aims at collecting return on capital in the form of interest and that this will be deductible for tax purposes as a result. READ MORE
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4. Thin Capitalisation : A comparison of the application of article 9.1of the OECD model tax convention and the Swedish adjustment rule to thin capitalisation
University essay from IHH, RättsvetenskapAbstract : This thesis answers the question “How does the application of the Swedish adjustment rule correspond to the OECD point of view regarding intragroup loans to thinly capitalised companies?” The question is answered by using the traditional legal method and by examining the way the adjustment rule is applied by the Supreme Administrative Court, the Swedish approach when using the arm’s length principle in Swedish law is then compared to the approach recommended by the OECD. From a tax point of view intragroup prices on commodities and services are of vital importance for multinational enterprises, since these prices in the end affects the total corporate taxation. READ MORE
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5. The Implications of the Arbitration Convention : A step back for the European Community or a step forward for elimination of transfer pricing related double taxation?
University essay from IHH, RättsvetenskapAbstract : It was assumed in the mid 1990s that 60% of all global trade took place within a group of enterprises. With increased globalisation leading to an increase in mergers and acquisitions this figure is most likely higher. Thus intra-company and intra-group transactions form a major part of business. READ MORE
