Essays about: "economic double taxation"

Showing result 1 - 5 of 21 essays containing the words economic double taxation.

  1. 1. Transfer pricing adjustments derived from state aid cases - Are corresponding adjustments mandatory for EU Member States?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Ruby Michelle De Fátima Rojas Ixtacuy; [2022]
    Keywords : Corresponding adjustments; State Aid; Transfer pricing; Dispute Resolution Mechanisms; Arbitration; OCDE; double economic taxation; EU Member States; EU tax law; Tax Law; Law and Political Science;

    Abstract : When an EU MS executes a state aid recovery decision, specifically those cases regarding Advance Pricing Agreements (APAs), an economic double taxation issue and a potential TP dispute may arise, which could be generated by the need for the application of a corresponding adjustment. In any case, each jurisdiction has the discretion to determine if the application of a corresponding adjustment should be made. READ MORE

  2. 2. The Distribution Tax Regime Paradox - Compatibility of Estonian Tax Treatment of Non-Residents’ Capital Gains from Alienation of Immovable Property with European Law

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Henri Ahtiainen; [2022]
    Keywords : Taxation; EU Tax Law; Corporate income tax; witholding tax; capital gains; immovable property; real estate income; freedom of establishment; free movement of capital; distribution tax; principle of territoriality; balanced allocation of taxing rights; Law and Political Science;

    Abstract : The four fundamental freedoms granted to residents in the Community have become the pillars for fairness between economic operators and persons within the internal market. The aim of the freedoms is to prohibit any restriction or discrimination toward residents of another Member State and endorse equal treatment. READ MORE

  3. 3. Comparability Approaches of the CJEU Regards Dividends Received by Non-Resident CIVs: Is the Primary Law Sufficient or Not?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Serra Tor; [2020]
    Keywords : CIV-Investment Fund- Pension Fund-Withholding tax-Discrimination-TFEU Freedoms-Free Movement of Capital-Freedom of Establishment - OECD Model Convention 2017 - OECD s Commentary- UCITS Directive- AIFM Directive; Law and Political Science;

    Abstract : For preventing economic double taxation and neutralization of choice between direct and indirect investments, states might grant domestic funds certain tax advantages while not extending it to non-residents, which possibly result in international double taxation. This issue arises mostly because of the different features of the investment funds. READ MORE

  4. 4. Allocation of Taxing Rights of Occupational Pension in Cross-Border Situations between an ETT- and EET- or TET-system : An Analysis between Sweden and Portugal

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Miranda Stenlund; [2020]
    Keywords : Private occupational pension; Cross-border situations; Allocation of taxing rights; Sweden; Portugal; Tax treaties; ETT-system; EET-system; TET-system;

    Abstract : The fact that pension consists of three cashflows that can be taxed at different points in time has resulted in a great divergence in how states treat the income of pension. Nonetheless, a majority of tax treaties allocate the exclusive taxing rights of private occupational pension to the residence state as advocated by the Organisation for Economic Co-operation and Development. READ MORE

  5. 5. A legal study into the EU’s approach towards exit taxation

    University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

    Author : Patricia Zakrzewska; [2020]
    Keywords : direct taxation; EU law; exit taxation; ATAD; anti-tax avoidance directive; Law and Political Science;

    Abstract : The purpose of the thesis is to analyse the EU’s and CJEU’s approach towards exit taxes by finding guidance on how the exit tax rules shall be made to be considered as compatible with the requirements of EU law. The EU law’s presumption of establishing an internal market without boundaries at the frontiers prohibits national measures which hinder, inter alia, the market access. READ MORE