Essays about: "internal erosion"

Showing result 21 - 25 of 26 essays containing the words internal erosion.

  1. 21. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Margret Agusta Sigurdardottir; [2016]
    Keywords : Tax; Taxation; Tax Law; Direct Taxation; Fundamental Freedoms; Double Taxation; Double Non-Taxation; Tax Avoidance; Aggressive Tax Planning; The Single Tax Principle; Single Taxation; Tax Treaty Law; GAAR; General Anti-Abuse Rule; Exemption Method; Credit Method; Dividend; Interest; Classification of Income; International Tax Regime; ECJ Case Law; Hybrid Mismatch Arrangements; Hybrid Financial Instruments; Parent-Subsidiary Directive; Base Erosion and Profit Shifting; BEPS; BEPS Action Plan 2; Anti-Hybrid Rules; Linking Rules; Correspondence Principle; Anti-Tax Avoidance Directive Proposal; Parent-Subsidiary Directive Amendments; Justification Grounds; EU Law; Law and Political Science;

    Abstract : The purpose of the thesis is to analyse the problems of hybrid mismatch arrangements within the EU and how single taxation, which requires income to be taxed once, not more or less, can be secured under EU law. After the amendments of the Parent-Subsidiary Directive (PSD), where an anti-hybrid rule was enacted, the legal environment for companies within the European Union changed. READ MORE

  2. 22. Internal erosion in the pervious foundation of an embankment dam : A case study on the Lossen dam

    University essay from KTH/Vattendragsteknik

    Author : Gabriella Molinder; [2016]
    Keywords : seepage; internal erosion; suffusion; contact erosion; embankment dams;

    Abstract : The Lossen dam is an embankment dam in the Swedish river Ljusnan. The dam is founded on thick layers of stratified glaciofluvial sediments and till. Ever since construction, there have been problems with high pore pressures, large seepage flows and springs downstream of the right part of the dam. READ MORE

  3. 23. Does the LOB clause in BEPS Action 6 violate the principle of MFN treatment in EU law?

    University essay from Lunds universitet/Juridiska institutionen

    Author : Sascha Åkerman; [2016]
    Keywords : tax law; EU law; BEPS; tax planning; tax avoidance; aggressive tax planning; LOB clause; LOB rule; limitation on benefit; MFN treatment; MFN principle; principle of MFN treatment; ACT Group Litigation case; Sopora case; D case; Orange European Smallcap Fund case; WTO; GATT; Law and Political Science;

    Abstract : OECD delivered on October 5th 2015 the BEPS final package consisting of 15 actions intending to address the issues of base erosion and profit shifting. The aim of Action 6 is to prevent treaty abuse, in particular treaty shopping. READ MORE

  4. 24. Modelling internal erosion within an embankment dam prior to breaching

    University essay from KTH/Jord- och bergmekanik

    Author : Alejandro Vazquez Borragan; [2015]
    Keywords : internal erosion; numerical modelling; monitoring; embankment dam; risk analysis;

    Abstract : There are still uncertainties in the safety of existing embankment dams. For instance, the majority of embankment dams in Sweden were built between 1950s and 1970s, designed and constructed to standards that might be unacceptable nowadays. READ MORE

  5. 25. Transfer Pricing Documentation : - In Need Of A Harmonization?

    University essay from Högskolan i Jönköping/IHH, Rättsvetenskap

    Author : Richard Sandström; Puja Karimzadeh; [2014]
    Keywords : ;

    Abstract : In today's global world where internal cross-border transactions are made in a vast amount and thereby affect the economy to a large extent the area of transfer pricing has become more important than ever. Therefore the organization for economic co-operation and de-velopment (OECD) have started the base erosion and profit shifting project which aims to prevent the exploiting of gaps and differences of regulations in different states in cross-border transactions. READ MORE