Essays about: "beps problem"
Found 5 essays containing the words beps problem.
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1. Problems caused by unilateral measures while taxing the digital economy: Does the value creation approach suggested by OECD solve the problem?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This thesis examines the challenges arising from unilateral measures taken by both developing and developed countries to protect their taxing rights in the digital economy, leading to issues of double taxation. It focuses on India's equalisation levy and the UK's diverted profits tax (DPT) as examples of unilateral measures. READ MORE
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2. 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
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3. Aggressive Measures for Aggressive Schemes: Human Rights Perspectives
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The focus of this thesis is the EU Directive on mandatory disclosure rules on intermediaries that make available potentially aggressive cross-border tax arrangements. Its avowed purpose is to arrest base erosion and to address fairness in taxation. READ MORE
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4. Limitations on interest deductions: does BEPS action 4 presume tax avoidance?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Debt and equity are in most countries treated differently for taxing purposes. The asymmetry between the financing forms are being taken advantage of by MNEs, allowing them to plan their cross-border activities in a way that lowers the taxable burden for the whole group. READ MORE
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5. Transfer Pricing Treatment of Transactions with Hard-to-Value Intangibles: Is BEPS Action 8 Based on the Arm’s Length Principle?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This master’s thesis analyses BEPS Action 8 recommendations in relation to transactions with hard-to-value intangibles. OECD has developed them with a view to ensure that transfer pricing outcomes of transactions with hard-to-value intangibles are aligned with value creation. READ MORE
