Essays about: "international tax law"

Showing result 1 - 5 of 83 essays containing the words international tax law.

  1. 1. Does the Substance over Form approach implemented as a result of the BEPS package reconciles the Permanent Establishment definition with the existence of economic allegiances?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Moisés Zúñiga Vargas; [2019]
    Keywords : Taxes; Permanent Establishment; economic allegiances; MLI; OECD; BEPS; Model Tax Convention; International taxation; Law and Political Science;

    Abstract : The Permanent Establishment (PE) concept plays a key role in the distribution of taxing rights between States by determining when the profits derived by an entity are taxable in a State other than the State of its residency. This concept, originally, evidenced the existence of sufficient economic allegiances between a non-resident entity and a State to justify taxation therein. READ MORE

  2. 2. Rethinking traditional source concepts in a digital economy

    University essay from Uppsala universitet/Juridiska institutionen

    Author : George Daniel Costache; [2019]
    Keywords : International; tax law; OECD; digital economy; BEPS; Action 1; EU law; digital PE; DST; tax law; source taxation;

    Abstract : The purpose of this thesis is to provide meaningful understanding of the current state of business activities, which generates the need for implementing new taxing measures, analyse the challenges arising from this need, as well as their cause. Furthermore, the aforementioned challenges will be explained in the context of existing traditional taxing systems and proposed measures will be analysed. READ MORE

  3. 3. Death and Taxes : Analysis and Comparison of Bilateral International Succession TaxTreaty Structures Between the United States and Selected OECDStates

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Alex Galle-From; [2019]
    Keywords : Law; Tax; International Tax; International; Estate Tax; Inheritance Tax; Gift Tax; United States; OECD; Tax Treaty;

    Abstract : .... READ MORE

  4. 4. Thin Capitalization in the OECD, the EU and Sweden: policy responses, evaluation and alternatives.

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

    Author : Sotirios Apostolou; [2018]
    Keywords : Tax law; OECD; BEPS; BEPS Action 4; EU; ATAD; Thin Capitalization; debt bias; tax planning; tax shield; interest deduction; interest deduction limitation; interest deduction limitation rule; EBITDA; CBIT; ACE; ACC; COCA; AGI; Law and Political Science;

    Abstract : The issue of thin capitalization has risen in importance in recent years, to the point that it warranted international action. That action came in the form of Action 4 of the OECD BEPS Project, of Article 4 of the EU ATAD and of the new interest deduction limitation rules in the national Swedish legislation. READ MORE

  5. 5. European Commission's proposal to implement a new permanent establishment nexus based on significant digital presence - Is it compliant with the EU Law and international tax principles?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Lara Nogueira; [2018]
    Keywords : Taxation of the Digital Economy; New permanent establishment nexus based on significant digital presence; Proportionality of the proposal and its compatibility with the Ottawa Principles.; Law and Political Science;

    Abstract : The taxation of the digital economy has become a relevant subject, as business models and value creation chains of all sectors have been transformed bringing challenges to the international tax system and parameters for the allocation of taxing rights between source and residence jurisdictions. In view of these changes, the European Commission has published two proposals for directives on the taxation of digital activities, proposing solutions to be harmonized into the system of direct taxation of Member States. READ MORE