Essays about: "interpretation of tax treaties"
Showing result 1 - 5 of 15 essays containing the words interpretation of tax treaties.
-
1. In What Way Does the Russian GAAR Comply With EU ATAD and BEPS Rules?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The issues of tackling aggressive tax planning are actual throughout the whole history of global market economy. Earlier this struggle was held by the states individually through imposing rules into their national legislation authorizing tax supervisory bodies to use new methods of control, establishing liability for tax evasion, and developing the approaches by judgements of the courts on relevant cases. READ MORE
-
2. Interpretation and qualification of short-term employment in cross-border situation at Article 15(2)OECD MC
University essay from Uppsala universitet/Juridiska institutionenAbstract : The free movement of people and capital has enabled individuals and businesses to engage in cross-border transactions. Global economy and the competitiveness between international groups have acknowledged the necessity for a dynamic human workforce and openness of the labour market for mobility of workers within affiliated companies and different multinational enterprises. READ MORE
-
3. Beneficial Ownership - a concept in identity crisis
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : The aim of this thesis is to analyze and determine the meaning of the term “Beneficial Owner”, in the model treaty of the OECD and therefore its meaning in bilateral negotiated treaties based on the model treaty. The term’s legacy and application is presented. READ MORE
-
4. Reservations and Compatibility Clauses in the Multilateral Instrument: Overcoming New Interpretative Challenges
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Adopted on November 2016, the Multilateral instrument for BEPS tax treaty measures (MLI) has come into play in the global tax treaty landscape. The MLI is a multilateral agreement that aims for a speedy implementation of the treaty measures agreed upon in the Base Erosion and Profit Shifting (BEPS) Project by allowing the modification of the bilateral double tax treaties (DTTs) without the need of individual negotiation of each treaty. READ MORE
-
5. Exit Taxation in the European Union, Is there really a problem?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Exit taxes represent an expression of state’s sovereignty by taxing value increases of assets, hidden reserves and any untaxed income that arose on its territory. These taxes are triggered before the state of emigration loses its power of taxation as a result of the transfer to the jurisdiction of another state when an individual or company changes residency. READ MORE
