Essays about: "anti-avoidance"
Showing result 11 - 15 of 17 essays containing the word anti-avoidance.
-
11. General Anti-Avoidance Rules and the rule of law
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : Generella skatteflyktsregler, eller GAARs (general anti-avoidance rules), är legislativa åtgärder mot skatteflykt. GAARs typiska struktur består av två förutsättningar: skattebetalarens syfte och lagstiftarens syfte. READ MORE
-
12. 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
-
13. Linking Rules Assessed Against European and National Legal Benchmarks - A Juridical Remedy to Mitigate Double Non-Taxation?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This thesis provides a comprehensive analysis of linking rules, which were adapted as one of the alleged remedies against base erosion by the EU and the OECD. A number of issues emerge in connection with those recommended rules. This thesis will thus assess compliance of those rules against domestic and European legal benchmarks. READ MORE
-
14. Comparative Analysis of the United Kingdom Judicial Anti- Avoidance Rule and GAAR of Canada - Lesson for the UK from Canada
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This article examines whether the current UK judicial approach is an adequacy of the judicial approach Rule of law and GAAR and studies the historical experience of Canada with its statutory solutions. Based on the comparative study background, the article considers to a large extent, a statutory general anti-avoidance principle might assist with the problems of statutory interpretation in the United Kingdom. READ MORE
-
15. Applicability of domestic anti-avoidance legislation in relation to tax treaty commitments - A case study placing Swedish law in an international doctrinal framework
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The present paper is an analysis of Swedish law, as expressed obiter dictum in the Supreme Administrative Court decision of HFD 2012 ref. 20, regarding applicability of Swedish general anti avoidance rules in relation to tax treaty commitments. The purpose of the paper is to put Swedish law, as envisaged by HFD 2012 ref. READ MORE
