Essays about: "profit-allocation"

Found 4 essays containing the word profit-allocation.

  1. 1. The digital economy and its implications: does the OECD’s Pillar One Proposal challenge the principles of law within International and EU tax law?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Wihan Esterhuizen; [2023]
    Keywords : Tax; EU Law; OECD S Pillar One; principles of law; ability-to-pay; territoriality; state aid; transfer pricing; Arm s length principle; Law and Political Science;

    Abstract : Change is the only constant; yet, as we step into the brave new world of taxing the digital economy, it might seem like the need and development of principles and rules for adequate profit allocation has only begun. This thesis discusses the profit allocation rules under the Unified Approach of the OECD Pillar One Proposal Amount A in relation to three identified principles of law in international and European tax law. READ MORE

  2. 2. Profit-allocation based on value creation in the digital economy

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Tim Theunis; [2018]
    Keywords : Digital economy; value creation; tax; taxation; profit-allocation; permanent establishment; digital permanent establishment; virtual permanent establishment; formulary apportionment; arm s length principle; BEPS Action 1; BEPS Action 7; digitalization; digitalisation; European Commission; Directive; attribution of profits; value drivers; user jurisdiction; data; profit split method; transfer pricing; Law and Political Science;

    Abstract : With the proposed Directive by the European Commission to tax the digital economy more effective by introducing a digital permanent establishment, the question raises how to effectively tax it. Under the current profit-allocation principles, profits are allocated to the jurisdiction in which the significant people functions are situated. READ MORE

  3. 3. Forecasting Performance on Opportunistic Real Estate Investments

    University essay from KTH/Fastigheter och byggande

    Author : Jakob Paljak; Per Edenström; [2013]
    Keywords : commercial real estate; opportunistic investments; real estate funds; underwriting; cash flows; outcomes;

    Abstract : This thesis investigates the difficulty in making accurate forecasts on opportunistic commercial real estate investments. The purpose is to quantify the differences between unlevered cash flows from underwriting estimates and actual outcomes, analyse them and arrive at conclusions about the difficulty in producing forecasts on opportunistic investments. READ MORE

  4. 4. Forecasting Performance on Opportunistic Real Estate Investments

    University essay from KTH/Fastigheter och byggande

    Author : Jakob Paljak; Per Edenström; [2013]
    Keywords : commercial real estate; opportunistic investments; real estate funds; underwriting; cash flows; outcomes;

    Abstract : This thesis investigates the difficulty in making accurate forecasts on opportunistic commercial real estate investments. The purpose is to quantify the differences between unlevered cash flows from underwriting estimates and actual outcomes, analyse them and arrive at conclusions about the difficulty in producing forecasts on opportunistic investments. READ MORE