Essays about: "Treaty Shopping"

Showing result 1 - 5 of 14 essays containing the words Treaty Shopping.

  1. 1. Nationality requirements under ICSID: Treaty shopping and shell companies as conduits for foreign investors : An analytical study of the techniques used by investors to engage in treaty shopping and existing possible solutions.

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Safia Altaleb; [2022]
    Keywords : ;

    Abstract : .... READ MORE

  3. 2. The efficiency of the European Union’s Anti-money laundering legislation : An analysis of the legal basis and the harmonisation of the EU Anti-money laundering legal framework

    University essay from Stockholms universitet/Juridiska institutionen

    Author : David Muradyan; [2022]
    Keywords : ;

    Abstract : The purpose of this thesis is to examine the efficiency of the EU Anti-money laundering legislation in the light of a coherent and broad scope of legislative framework. To achieve this purpose, the thesis examines firstly the legal basis of an EU Anti-money laundering legislation in general. READ MORE

  4. 3. 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. 4. Does the LOB clause in BEPS Action 6 violate the principle of MFN treatment in EU law?

    University essay from Lunds universitet/Juridiska institutionen

    Author : Sascha Åkerman; [2016]
    Keywords : tax law; EU law; BEPS; tax planning; tax avoidance; aggressive tax planning; LOB clause; LOB rule; limitation on benefit; MFN treatment; MFN principle; principle of MFN treatment; ACT Group Litigation case; Sopora case; D case; Orange European Smallcap Fund case; WTO; GATT; Law and Political Science;

    Abstract : OECD delivered on October 5th 2015 the BEPS final package consisting of 15 actions intending to address the issues of base erosion and profit shifting. The aim of Action 6 is to prevent treaty abuse, in particular treaty shopping. READ MORE

  6. 5. The Principal Purpose Test under BEPS Action 6: Does the OECD Proposal Fit the EU Legal Framework?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Oleksandr Koriak; [2016]
    Keywords : Treaty Shopping; Treaty Abuse; BEPS; GAAR; PPT; Principal Purpose Test; Anti-Abuse Rules; EU Fundamental Freedoms; Law and Political Science;

    Abstract : On October 5, 2015, the Organization for Economic Cooperation and Development published the final package of 15 actions under the BEPS initiative. This package, in particular, includes the Final Report on Action 6 – ‘Preventing the granting of treaty benefits in inappropriate circumstances’, which is intended to provide countries with the ‘minimum level of protection against treaty abuse’. READ MORE