Essays about: "international taxation law"

Showing result 26 - 30 of 64 essays containing the words international taxation law.

  1. 26. 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

  2. 27. 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

  3. 28. 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

  4. 29. Aggressive Measures for Aggressive Schemes: Human Rights Perspectives

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Danilo Penetrante Ventajar; [2018]
    Keywords : Taxation; Human Rights; BEPS; BEPS Action Plan 12; Mandatory Disclosure Rules; Aggressive Tax Planning; Abusive Tax Planning; Tax Avoidance; Fairness; ECHR; EU Charter of Fundamental Rights; Directive on Administrative Cooperation; DAC; DAC6; right to property; right to privacy; right to fair trial; LPP; Law and Political Science;

    Abstract : The focus of this thesis is the EU Directive on mandatory disclosure rules on intermediaries that make available potentially aggressive cross-border tax arrangements. Its avowed purpose is to arrest base erosion and to address fairness in taxation. READ MORE

  5. 30. Compensating adjustments - An international perspective

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

    Author : Oskar Paladini Söderberg; [2018]
    Keywords : Skatterätt; finansrätt; fiscal law; transfer pricing; compensating adjustments; economic double taxation; Law and Political Science;

    Abstract : The purpose of this essay is to investigate if there exist any differences in the handling of compensating adjustments between Sweden and the UK and why these differences exist together with what consequences it may bring. Differences were identified, such as the fact that the UK only allows for compensating adjustments in an upward direction whilst Sweden accepts adjustments in both directions. READ MORE