Essays about: "international tax law"

Showing result 1 - 5 of 80 essays containing the words international tax law.

  1. 1. 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

  2. 2. 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

  3. 3. Does the taxation of permanent establishment ensure source-based taxation on business profits? - An analysis of cross-border services

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Thanissorn Masuchand; [2018]
    Keywords : permanent establishment; Law and Political Science;

    Abstract : Services belong to the business sector which contributes most to the world’s economy. Despite that there is no specific provision in the OECD Model Tax Convention which concerns the taxation of business services specifically. READ MORE

  4. 4. Tangible Intangibles in the United States’ Tax Cuts and Jobs Act : How Mixed Definitions of “Intangible” Lead to Mixed Results in the United States’ Efforts to Close Tax Loopholes, Move to a Territorial Tax System, and Reduce Base Erosion and Profit Shifting Abuses

    University essay from Uppsala universitet/Juridiska institutionen

    Author : James Summers; [2018]
    Keywords : tax; law; international tax law; intangible; tangible; property; income; definition; territorial tax system; worldwide tax system; OECD; WTO; United States; TCJA;

    Abstract : The United States’ Tax Cuts and Jobs Act of 2017 (TCJA) changed a 30-year-old definition of the term “intangible property” and added assessment requirements for two different types of “intangible income”, both of which deviate from the newly changed general definition of “intangible” and most common understandings of the meaning of the word.  While it may appear unlikely that a change in meaning of a single word in a large tax code could have a drastic effect on international taxation, the differing definitions of “intangible” create far-reaching tangible consequences. READ MORE

  5. 5. General Anti-Avoidance Rules and Legal Certainty in Sweden, USA and China – A taxation determined by legal culture?

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

    Author : Markus Nyberg Andersson; [2018]
    Keywords : Tax Avoidance; Legal Certainty; GAAR; Sweden; United States; USA; U.S.; China; General Anti-Avoidance Rules; Tax law; skatterätt; internationell skatterätt; international tax law; ATAD; BEPS Project; Chinese GAAR; SAAR; OECD; Swedish GAAR; U.S. GAAR; People s Republic of China; Law and Political Science;

    Abstract : The occurrence of taxpayers implementing arrangements without commercial purpose to avoid tax laws and reduce their taxation, id est tax avoidance, is counteracted in most legal systems with different methods. Most jurisdictions have implemented not only Specific Anti-Avoidance Rules ("SAARs"), but also General Anti Avoidance Rules ("GAARs") to counteract tax avoidance. READ MORE