Advanced search

Showing result 1 - 5 of 90 essays matching the above criteria.

  1. 1. The Brazilian Adoption of the Arm's Length Principle : Considerations and its Impact on the Country's Fiscal Sovereignty in Cross-border Commodities Transactions

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Alexandre Magno Ramos Paiva; [2023]
    Keywords : Arm’s Length Principle; Practicability Principle; Transfer Pricing; Fiscal Sovereignty; Commodities.;

    Abstract : The thesis critically examines the Brazilian adoption of arm's length principle and assesses its impact on the country's fiscal sovereignty in cross-border commodities transactions. The arm's length principle is regarded as an useful tool for preventing tax avoidance and ensuring tax neutrality. READ MORE

  3. 2. Tax Avoidance, Aggressive Tax Planning, and the United States’ Tax Cuts and Jobs Act of 2017 : An Investigation into Anti-Base Erosion and Anti-Profit Shifting Strategies

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Andrea Rosato; [2022]
    Keywords : tax; international tax; OECD; BEPS; Pillar 2; base erosion; profit shifting; anti-avoidance; corporate inversions; TCJA; tax cuts and jobs act; United States; US; law; US tax law; international tax law; taxation; tax planning; aggressive tax planning;

    Abstract : .... READ MORE

  4. 3. Eu State Aid Rules And Corporate Direct Tax Arrangements : An Analysis of Article 107(1) TFEU and Recent case Developments with the principle of Legality

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Sharon Mame Sika Värttö; [2022]
    Keywords : State aid; Tax ruling; Tax avoidance; Hybrid arrangement; Aid recovery; Legality; Legal certainty; Selective advantage; Harmful tax competition; Transfer pricing; Arm’s length principle; Economic advantage.;

    Abstract : The European Union was devised to promote competition in the international market environment and ensure balanced allocation of fiscal and political requirements of the Member States. Globalization has led to enabling tax environments through granting of tax benefits by EU Member jurisdictions intended to promote competition in attracting foreign investment, trade, and development. READ MORE

  5. 4. The General Anti-Avoidance Rules in International Tax Law and the Rule of Law – The Issue of Predictability and Taxpayers’ Rights

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Rufus Bloh Senyon; [2022]
    Keywords : GAAR; OECD Treaty GAAR; EU GAAR; Taxpayers Rights and Fuller s Morality of Law Principles;

    Abstract : This paper addresses a principle in international taxation that has long been a subject of controversy in many countries regarding the countering of abusive maneuverings in tax matters and had engendered debates amongst academic scholars concerning its predictibility. This anti-abuse principle, doctrine or clause in international tax matters had over the years received many names according to variant applied in each country. READ MORE

  6. 5. Link between Transfer Pricing and Customs Union Regulations

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Ankita Tiwari; [2022]
    Keywords : Transfer Pricing; Customs Union;

    Abstract : Base erosion and profit sharing (BEPS) explain the process when multinational enterprises take advantage of the gaps, mismatches or loopholes in the international tax regulations for artificially shifting profits to lower tax jurisdictions or no tax jurisdictions. Tax avoidance strategies were legal in most cases and overlooked until the OECD G20 BEPS project was done in 2013. READ MORE