Essays about: "direct taxation"

Showing result 21 - 25 of 64 essays containing the words direct taxation.

1. 21. Neutralizing the Effects of Hybrid Mismatch Arrangements on a EU Level - To what extent can Member States be obliged to align their tax systems to each other?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Juliane Fiebig; [2016]
   Keywords : Hybrid Mismatches; Hybrid Financial Instruments; Double Taxation; Double Non-Taxation; Tax Abuse; BEPS; Anti-Tax Tax Avoidance; Tax Arbitrage; Law and Political Science;

   Abstract : Due to the on-going discussion regarding the OECD/G20 BEPS project and its particular actions it is an important task for the EU legislator to establish a reasonable and functional legal framework in order to ensure a certain degree of uniformity of Anti-BEPS measures within the European Union. In doing so, the protagonists must respect the boundaries set to domestic law as well as to measures of secondary legislation by primary EU law. READ MORE

3. 22. A Comparative Approach to the Order of Priority of the Allocation of Taxing Rights over Business Profits in the OECD MC, the UN MC and the Andean Pact MC – The PE broadening. An Argentinean example.

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Laura Mariel Alejandro; [2015]
   Keywords : OECD Model Convention; UN Model Convention; Andean Community; Andean Pact Model; Business Profits; Service PE; Service Permanent Establishment; Delivery PE; Delivery Permanent Establishment; Permanent Establishment; Argentina; Allocation of Business Profits; PE threshold; BEPS; Profit Split Method; Formulary Profit Split; Business and Economics;

   Abstract : The current OECD´s PE threshold requires either a direct physical presence (fixed place of business) or an indirect presence through a legal representative (dependent agent). On the other hand, Model Conventions such as the UN MC, provide a wider PE threshold, including income generating activities which are not included under the OECD PE threshold. READ MORE

4. 23. Labour Taxation and Greenfield FDI Decisions - The Case of OECD Countries

   University essay from Handelshögskolan i Stockholm/Institutionen för nationalekonomi

   Author : Petronella Berke; Julia Wangenheim; [2015]
   Keywords : foreign direct investment; labour taxation; corporate taxation;

   Abstract : This thesis investigates the impact of labour taxation on greenfield FDI decisions in OECD countries between the years 2003 and 2013, using panel data and both fixed effects and first differences models. The findings suggest that labour taxation has a statistically significant negative impact on the discrete decision whether to invest or not. READ MORE

5. 24. Developing Issues on Withholding Tax on Outgoing Dividends in the European Union

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Joel Uddenäs; [2015]
   Keywords : Withholding tax; Internal market; Tax Sovereignty; Dividend payments; Comparable Situation; Law and Political Science;

   Abstract : The European Court of Justice has repeatedly held that it is contrary to EU-law to charge withholding tax on cross-border dividend payments when comparable, domestic transactions are not taxed at the corresponding burden. Therefore, the question of withholding taxes compatibility with EU-law has been the topic of extensive legal literature over many years. READ MORE

6. 25. The transition from CCC to UCC with regard to royalties and license fees, and necessary consequences for the VAT-Directive

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Terence Tervoort; [2015]
   Keywords : GATT; Royalties and License fees; Customs Value; European Customs Law; Transition from CCC to UCC; Import VAT; Law and Political Science;

   Abstract : As the Union Customs Code will replace the Community Customs Code with effect from 1 May 2016, the thesis focuses on the new treatment of royalty payments for customs purposes and its legal consequences. In a first step, a comparison between the Community Customs Code and the Union Customs Code reveals that importers will have to face a significant increase in the customs liability of royalty payments. READ MORE