Essays about: "arm’s length principle"
Showing result 1 - 5 of 28 essays containing the words arm’s length principle.
-
1. The Brazilian Adoption of the Arm's Length Principle : Considerations and its Impact on the Country's Fiscal Sovereignty in Cross-border Commodities Transactions
University essay from Uppsala universitet/Juridiska institutionenAbstract : The thesis critically examines the Brazilian adoption of arm's length principle and assesses its impact on the country's fiscal sovereignty in cross-border commodities transactions. The arm's length principle is regarded as an useful tool for preventing tax avoidance and ensuring tax neutrality. READ MORE
-
2. The digital economy and its implications: does the OECD’s Pillar One Proposal challenge the principles of law within International and EU tax law?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Change is the only constant; yet, as we step into the brave new world of taxing the digital economy, it might seem like the need and development of principles and rules for adequate profit allocation has only begun. This thesis discusses the profit allocation rules under the Unified Approach of the OECD Pillar One Proposal Amount A in relation to three identified principles of law in international and European tax law. READ MORE
-
3. Is control over risk getting out of control? : An analysis of the concept of control over risk as set out in the 2022 OECD Guidelines in relation to Swedish law
University essay from Uppsala universitet/Juridiska institutionenAbstract : In 2017 an amended version of the OECD Transfer Pricing Guidelines was published which included new provisions to prevent BEPS through the shifting of risks. Through the amendment of the Guidelines, it was clarified that for an entity in an MNE to contractually assume a risk, for transfer pricing purposes, it needs to control the risk and have the financial capacity to assume it. READ MORE
-
4. The Commission’s Approach in State Aid Assessment of Advance Pricing Agreements: an Autonomous EU Arm’s Length Principle and Its Implications
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : This thesis aims to reveal whether the Commission’s approach in the State aid assessment of advance pricing agreements (APAs) is in line with the current EU law framework and whether, given its implications, it is a sensible development in State aid law applied to taxation. Chapter 2 introduces the background of the arm's length principle, looking into its origin, purpose and application in tax law. READ MORE
-
5. Can the Arm’s Length Principle in the OECD Transfer Pricing Guidelines Fulfil the Minimum Requirements of the Transaction Approach in the Controlled Foreign Company Rules under Anti-Tax Avoidance Directive?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Generally, the ALP in TP regulations is widely applied in order to prevent price manipulation which will cause tax avoidance. And CFC regulations have usually been regarded as a “backstop” of TP regulations in terms of combating tax avoidance. READ MORE
