Essays about: "international taxation law"
Showing result 36 - 40 of 64 essays containing the words international taxation law.
-
36. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The purpose of the thesis is to analyse the problems of hybrid mismatch arrangements within the EU and how single taxation, which requires income to be taxed once, not more or less, can be secured under EU law. After the amendments of the Parent-Subsidiary Directive (PSD), where an anti-hybrid rule was enacted, the legal environment for companies within the European Union changed. READ MORE
-
37. Cross-border Loss Utilization Concerning the Tax Treatment of a Taxpayer’s Own Losses Attributable to a Permanent Establishment in Relation to the Territoriality Principle –From an International and EU law Perspective
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The European Commission has acknowledged the lack of cross-border utilization of losses. Companies operating internationally want to have a possibility to offset losses against taxable profits at the same time or as soon as possible after the losses incurred. READ MORE
-
38. Potential double tax treaty override of South African exit taxation law – how do tax treaties allocate the right to tax unrealized gains?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : South African income tax legislation makes provision for the levying of exit taxes or charges when individuals emigrate from or companies cease to be residents or become headquarter companies, or when controlled foreign companies (CFC) cease to be CFCs otherwise than by way of becoming residents. As indicated by the title the discourse followed in this paper entails the analysis of treaties to ascertain the connecting factors employed by the OECD Model treaty giving rise to signatories levying exit taxes. READ MORE
-
39. PE Threshold for Business Profits in E-Commerce Context-To what extent does the present Permanent Establishment threshold influence the taxation of Electronic Commerce cross-border transactions?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Issues related to attribution of profits already exist in the traditional economic framework and are of a different nature, however these issues seem to become more bothersome in transactions conducted in e-commerce context, with an electronic economy. The matter is similar to the traditional economic problems in regard to transfer pricing adjustments; however these issues are much more complex due to the e-commerce nature, especially when considering the fact that multinational enterprises may gather data from different jurisdictions, and for different purposes, which makes the tracing of the source of the data highly complex. READ MORE
-
40. Taxation of Multi-National Enterprises - State and corporate responsibility regarding the issue of transfer pricing
University essay from Lunds universitet/Juridiska institutionenAbstract : Uppsatsen berör frågeställningen hur multinationella företag påverkar skattebasen via internprissättning. När företag överför tillgångar mellan enheter i olika länder krävs det att tillgångarna prissätts så att den beskattningsbara vinsten som uppkommer speglar omsättningen/värdet på enheten i det landet. READ MORE
