Essays about: "non-residents"
Showing result 11 - 15 of 17 essays containing the word non-residents.
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11. 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
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12. Neutralisation of discrimination in direct taxation: the problem of applicability from the perspective of tax treaties and 'opt in' domestic clauses
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The thesis provides the analysis of the concept of neutralisation based on the existing case law of the CJEU, AGs' opinions and academic writings. It introduces the reader to the meaning, scope and the purpose of neutralisation. READ MORE
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13. Prohibition of the Discriminatory Income Tax Measures under WTO Law
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The paper explores the relevance of the WTO non-discrimination undertaking in income taxation. Particularly, the national treatment obligation and the prohibition of export subsidies are analyzed. READ MORE
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14. The Treatment of dividend payments in EC Direct Tax Law
University essay from Lunds universitet/Juridiska institutionenAbstract : To attain an Internal Market, in which goods, capital and natural and legal persons can move from Member States to Member State, is one of the main aims of the EU. The Treaty of Rome was laid down in order to tear down obstacles that existed and to create bonds between the Member States. READ MORE
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15. An EC without withholding taxes? - The role of tax treaties in ECJ:s discrimination-assessment
University essay from Lunds universitet/Juridiska institutionenAbstract : It seems like it can never be said enough times: in order to uphold the objectives of the Internal Market, an equal treatment of resident and non-resident taxpayers have to be granted by the Member States. As for the intricate field of direct taxation, it is still somewhat unclear exactly how this equal treatment looks. READ MORE
