Essays about: "principle base rule base"

Showing result 1 - 5 of 10 essays containing the words principle base rule base.

  1. 1. Taxing the Digital Economy - A Legal Assessment of the Introduction of PIllar One to the Internal Market

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

    Author : Gabija Ramanauskaite; [2021]
    Keywords : EU Law; International tax law; OECD; Pillar One; Nexus; Law and Political Science;

    Abstract : In the last decade, the progress of the digital economy has caused a rift in the international tax regime, which now faces several challenges. The current principles governing taxation rules are based on notions that business can only be conducted through physical presence. READ MORE

  2. 2. The Organization of the Judiciary in EU Member States – an Internal Affair?

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Leona Mittermayer; [2020]
    Keywords : ;

    Abstract : Recent events in the Member States of the EU have shown that the common values of the Union, inter alia the rule of law, might not be guaranteed across the Union as once hoped for. Scholars speak of a “rule of law crisis” while the Parliament and the Commission have activated Article 7 TEU, the so called “nuclear option”, regarding the situation in two of the Union’s 27 Member States, namely Poland and Hungary. READ MORE

  3. 3. 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. 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

  5. 5. Does the LOB clause in BEPS Action 6 violate the principle of MFN treatment in EU law?

    University essay from Lunds universitet/Juridiska institutionen

    Author : Sascha Åkerman; [2016]
    Keywords : tax law; EU law; BEPS; tax planning; tax avoidance; aggressive tax planning; LOB clause; LOB rule; limitation on benefit; MFN treatment; MFN principle; principle of MFN treatment; ACT Group Litigation case; Sopora case; D case; Orange European Smallcap Fund case; WTO; GATT; Law and Political Science;

    Abstract : OECD delivered on October 5th 2015 the BEPS final package consisting of 15 actions intending to address the issues of base erosion and profit shifting. The aim of Action 6 is to prevent treaty abuse, in particular treaty shopping. READ MORE