Essays about: "international taxation law"

Showing result 1 - 5 of 64 essays containing the words international taxation law.

  1. 1. Compatibility of Income Inclusion rule with EU Law. : GLoBE IIR and EU Law.

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Ritu Pandey; [2023]
    Keywords : International tax; IIR GLoBE rule EU law;

    Abstract : In October 2021, 137 countries and jurisdictions agreed on a common approach towards a global minimum tax of 15% on the profits of large multinational companies that is referred to as the Pillar Two Model Rules, ‘Anti Global Base Erosion’, or ‘GloBE’ Rules. This political agreement implies that member countries who wish to implement such a tax regime have to streamline its design by modelling it after the so called Global Anti-Base Erosion Proposal (‘GloBE’) that the IF has developed as ‘Pillar 2’ of its work program on tax challenges arising from the digitalization of the economy. READ MORE

  2. 2. The Grey Area of Taxation - An essay on Low Value-Adding Services in Swedish Tax Law

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

    Author : Douglas Linton Wahlgren; [2023]
    Keywords : skatterätt; finansrätt; koncerninterna tjänster; internprissättning; vinstallokering; Law and Political Science;

    Abstract : This essay critically examines the legal aspects of low value-adding services within multinational corporations, focusing on their treatment in Swedish tax law and the OECD Transfer Pricing Guidelines (OECD TPG). It explores the challenges and complexities involved in defining and taxing intragroup services, emphasizing their impact on profit shifting strategies. READ MORE

  3. 3. Tax Avoidance, Aggressive Tax Planning, and the United States’ Tax Cuts and Jobs Act of 2017 : An Investigation into Anti-Base Erosion and Anti-Profit Shifting Strategies

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Andrea Rosato; [2022]
    Keywords : tax; international tax; OECD; BEPS; Pillar 2; base erosion; profit shifting; anti-avoidance; corporate inversions; TCJA; tax cuts and jobs act; United States; US; law; US tax law; international tax law; taxation; tax planning; aggressive tax planning;

    Abstract : .... READ MORE

  4. 4. How Multipolarity and Globalization Have Changed the Nature of Tax Multilateralism : A Comparison of the OECD Model Tax Convention Negotiation with the Negotiation of Pillar One and Two

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Daniel Raddenbach; [2022]
    Keywords : tax; taxation; globalization; international relations; negotiation; Pillar One; Pillar Two; OECD; model tax treaty; multilateralism; cooperation; tax multilateralism; global minimum tax; digital services; bilateralism;

    Abstract : Can a multilateral negotiating process—that is, cooperation between many states in a single forum—successfully reform the network of bilateral tax treaties that currently makes up the bulk of international tax law? The BEPS Project aims to be the first major push for a multilateral tax process since the creation of the OECD’s Model Tax Convention in the 1960s. Through BEPS, the OECD and 130-plus countries are in final negotiations to implement Pillar One and Two, which will: (1) create a new taxing right for “market jurisdiction” countries on the profit of international companies that do business there without a physical presence; and (2) implement a top-up tax levied against companies that offshore profits from intangible assets in low-tax jurisdictions. READ MORE

  5. 5. Taxation of influencers: A double taxation or a non-double taxation issue?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Andrea Del Pilar Valbuena Bernal; [2022]
    Keywords : Taxation; Individual Income Tax; Influencers; International Income Tax; OECD Model Convention.; Law and Political Science;

    Abstract : Although states have begun to regulate influencer activities in areas such as advertising and consumer protection, that is not the case in tax law. This research analyses various Tax Authority’s guidelines on the matter and concludes that the rules already in place in most jurisdictions are applied to influencers’ activities. READ MORE