Essays about: "model treaty"

Showing result 21 - 25 of 62 essays containing the words model treaty.

  1. 21. 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

  3. 22. Beneficial Ownership - a concept in identity crisis

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

    Author : Fredrik Hagmann; [2017]
    Keywords : tax law; skatterätt; international tax law; internationell skatterätt; tax treaty law; skatteavtalsrätt; beneficial owner; beneficial ownership; OECD; dividend; utdelning; interest; ränta; royalty; model treaty; modellavtalet; Law and Political Science;

    Abstract : 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. 23. The Definition of a Permanent Establishment in the BEPS Era : An analysis of the introduction of commissionaire structures in Article 5(5) of the OECD Model Treaty

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Camilla Berkesten Hägglund; [2017]
    Keywords : International tax law; Internationell skatterätt;

    Abstract : .... READ MORE

  5. 24. The effect of BITs, a two-sided story

    University essay from Lunds universitet/Nationalekonomiska institutionen

    Author : Emmy Lundblad; [2016]
    Keywords : BIT; Gravity model; FDI; Developed countries; TTIP; Business and Economics;

    Abstract : Bilateral Investment Treaty is an agreement designed to increase FDI between signatories. Historically the treaty is concluded between a developed country and a developing country, as a risk-lowering instrument. READ MORE

  6. 25. BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty - Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Johanna Fridh; [2016]
    Keywords : Tax treaty; tax treaty override; improper use of a tax treaty; anti-abuse rules; Limitation-on-benefits; Principal purpose test; General Anti-avoidance rules; BEPS; Action 6; agressive tax planning; Law and Political Science;

    Abstract : The thesis provides an overview of the relationship between tax treaties and domestic law and issues that arise if a contracting state uses domestic anti-avoidance rules to prevent the improper use of a tax treaty. Improper use of a tax treaty is an issue addressed in the BEPS Action 6 report. READ MORE