Essays about: "oecd double taxation"

Showing result 1 - 5 of 34 essays containing the words oecd double taxation.

  1. 1. Problems caused by unilateral measures while taxing the digital economy: Does the value creation approach suggested by OECD solve the problem?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Priyanka Kumari Prasad; [2023]
    Keywords : Unilateral measures; Equalisation levy; Diverted Profit Tax; Digital economy; Value creation approach; Juridical double taxation; OECD s Pillar One.; Law and Political Science;

    Abstract : This thesis examines the challenges arising from unilateral measures taken by both developing and developed countries to protect their taxing rights in the digital economy, leading to issues of double taxation. It focuses on India's equalisation levy and the UK's diverted profits tax (DPT) as examples of unilateral measures. READ MORE

  2. 2. Taxation of influencers: A double taxation or a non-double taxation issue?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Andrea Del Pilar Valbuena Bernal; [2022]
    Keywords : Taxation; Individual Income Tax; Influencers; International Income Tax; OECD Model Convention.; Law and Political Science;

    Abstract : Although states have begun to regulate influencer activities in areas such as advertising and consumer protection, that is not the case in tax law. This research analyses various Tax Authority’s guidelines on the matter and concludes that the rules already in place in most jurisdictions are applied to influencers’ activities. READ MORE

  3. 3. Secondary Transfer Pricing Adjustments: Interpretation Challenges within the EU and International Perspectives

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Andrii Falendysh; [2021]
    Keywords : tax law; transfer pricing; secondary transfer pricing adjustments; interpretation; PSD; parent-subsidiary directive; OECD MC; constructive dividends; constructive interest; constructive capital injection; secondary transaction; Law and Political Science;

    Abstract : This master thesis elaborates on the issues of the secondary transfer pricing adjustments that are common yet not regulated in an efficient manner by the states. The core problem of the double taxation issues to follow is the unwillingness of the states to accept the administrative tax decisions of each other in such sensitive fields as transfer pricing. READ MORE

  4. 4. The incompatible Definitions of Intangibles between the OECD Guidelines and the U.S. Tax Cuts and Jobs Act from a Transfer Pricing Perspective.

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Julia Hochreiter; [2020]
    Keywords : Transfer pricing; definition of intangibles; goodwill; ongoing concern value; double taxation; double non-taxation; the OECD Transfer Pricing Guidelines; the U.S. Tax Cuts and Jobs Act.; Law and Political Science;

    Abstract : “What discrepancies arise from the incompatible definitions of intangibles for transfer pricing purposes according to the OECD Transfer Pricing Guidelines 2017 and the U.S. READ MORE

  5. 5. Comparability Approaches of the CJEU Regards Dividends Received by Non-Resident CIVs: Is the Primary Law Sufficient or Not?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Serra Tor; [2020]
    Keywords : CIV-Investment Fund- Pension Fund-Withholding tax-Discrimination-TFEU Freedoms-Free Movement of Capital-Freedom of Establishment - OECD Model Convention 2017 - OECD s Commentary- UCITS Directive- AIFM Directive; Law and Political Science;

    Abstract : For preventing economic double taxation and neutralization of choice between direct and indirect investments, states might grant domestic funds certain tax advantages while not extending it to non-residents, which possibly result in international double taxation. This issue arises mostly because of the different features of the investment funds. READ MORE