Essays about: "international taxation law"

Showing result 1 - 5 of 43 essays containing the words international taxation 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. The Seeking of a Business-Optimal Transfer Price - In accordance with the Arm's Length Principle

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

    Author : Oskar Paladini Söderberg; [2019]
    Keywords : Transfer pricing; game theory; skatterätt; international taxation law; Arm s length principle; Law and Political Science;

    Abstract : The search of a business-optimal transfer price has been going on for decades. One interesting solution aimed to, by the use of game theory, bargaining theory and transfer pricing, create a quantitative solution to optimize the global profits of a multinational enterprise. READ MORE

  4. 4. 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

  5. 5. 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