Essays about: "parent-subsidiary directive"

Showing result 1 - 5 of 8 essays containing the words parent-subsidiary directive.

1. 1. 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

3. 2. In What Way Does the Russian GAAR Comply With EU ATAD and BEPS Rules?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Aleksei Shcherbakov; [2020]
   Keywords : Tax law; tax abuse; GAAR; ATAD; BEPS; CFC; EU law; Russian tax law; tax avoidance; Law and Political Science;

   Abstract : 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

4. 3. The Commission Proposal for a Directive on Double Taxation Dispute Resolution Mechanisms: Will it resolve the remaining double taxation issues within the EU?

   University essay from Lunds universitet/Juridiska institutionen

   Author : Jiawen Xi; [2017]
   Keywords : Double taxation; European Union; Double taxation resolution; Arbitration Convention; ATAD; Law and Political Science;

   Abstract : Double taxation has been widely accepted that constitutes an obstacle to the functioning of the single market. The European Union has adopted some uniform measures to have double taxation eliminated, for example, the Parent-Subsidiary Directive and the Interest-Royalty Directive. READ MORE

5. 4. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Margret Agusta Sigurdardottir; [2016]
   Keywords : Tax; Taxation; Tax Law; Direct Taxation; Fundamental Freedoms; Double Taxation; Double Non-Taxation; Tax Avoidance; Aggressive Tax Planning; The Single Tax Principle; Single Taxation; Tax Treaty Law; GAAR; General Anti-Abuse Rule; Exemption Method; Credit Method; Dividend; Interest; Classification of Income; International Tax Regime; ECJ Case Law; Hybrid Mismatch Arrangements; Hybrid Financial Instruments; Parent-Subsidiary Directive; Base Erosion and Profit Shifting; BEPS; BEPS Action Plan 2; Anti-Hybrid Rules; Linking Rules; Correspondence Principle; Anti-Tax Avoidance Directive Proposal; Parent-Subsidiary Directive Amendments; Justification Grounds; EU Law; Law and Political Science;

   Abstract : 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

6. 5. Neutralizing the Effects of Hybrid Mismatch Arrangements on a EU Level - To what extent can Member States be obliged to align their tax systems to each other?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Juliane Fiebig; [2016]
   Keywords : Hybrid Mismatches; Hybrid Financial Instruments; Double Taxation; Double Non-Taxation; Tax Abuse; BEPS; Anti-Tax Tax Avoidance; Tax Arbitrage; Law and Political Science;

   Abstract : Due to the on-going discussion regarding the OECD/G20 BEPS project and its particular actions it is an important task for the EU legislator to establish a reasonable and functional legal framework in order to ensure a certain degree of uniformity of Anti-BEPS measures within the European Union. In doing so, the protagonists must respect the boundaries set to domestic law as well as to measures of secondary legislation by primary EU law. READ MORE