Essays about: "tax treaty law"
Showing result 16 - 20 of 66 essays containing the words tax treaty law.
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16. Beneficial Ownership - a concept in identity crisis
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : The aim of this thesis is to analyze and determine the meaning of the term “Beneficial Owner”, in the model treaty of the OECD and therefore its meaning in bilateral negotiated treaties based on the model treaty. The term’s legacy and application is presented. READ MORE
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17. Reservations and Compatibility Clauses in the Multilateral Instrument: Overcoming New Interpretative Challenges
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Adopted on November 2016, the Multilateral instrument for BEPS tax treaty measures (MLI) has come into play in the global tax treaty landscape. The MLI is a multilateral agreement that aims for a speedy implementation of the treaty measures agreed upon in the Base Erosion and Profit Shifting (BEPS) Project by allowing the modification of the bilateral double tax treaties (DTTs) without the need of individual negotiation of each treaty. READ MORE
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18. The Definition of a Permanent Establishment in the BEPS Era : An analysis of the introduction of commissionaire structures in Article 5(5) of the OECD Model Treaty
University essay from Uppsala universitet/Juridiska institutionenAbstract : .... READ MORE
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19. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
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20. Is BEPS Action 6 “Preventing Treaty abuse” compatible with the EU Law concept of abuse?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of "granting treaty benefits in inappropriate circumstances". Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law. READ MORE