Essays about: "tax treaty law"
Showing result 21 - 25 of 66 essays containing the words tax treaty law.
-
21. BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty - Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The thesis provides an overview of the relationship between tax treaties and domestic law and issues that arise if a contracting state uses domestic anti-avoidance rules to prevent the improper use of a tax treaty. Improper use of a tax treaty is an issue addressed in the BEPS Action 6 report. READ MORE
-
22. Legal limits to promoting equity capital investments using fiscal measures - State aid perspective
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This contribution explores the area of tax law pertaining to treatment of debt and equity finance as well as devises recommendations for Member States of the European Union seeking to promote equity participation without the risk of infringing upon Community law provisions relating to State aid. The study begins with the presentation of the underlying issues pertaining to the choice between debt and equity finance as well as the notion of State aid as applicable in the field of fiscal measures. READ MORE
-
23. Does the LOB clause in BEPS Action 6 violate the principle of MFN treatment in EU law?
University essay from Lunds universitet/Juridiska institutionenAbstract : 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
-
24. The Principal Purpose Test under BEPS Action 6: Does the OECD Proposal Fit the EU Legal Framework?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : On October 5, 2015, the Organization for Economic Cooperation and Development published the final package of 15 actions under the BEPS initiative. This package, in particular, includes the Final Report on Action 6 – ‘Preventing the granting of treaty benefits in inappropriate circumstances’, which is intended to provide countries with the ‘minimum level of protection against treaty abuse’. READ MORE
-
25. Exit Taxation in the European Union, Is there really a problem?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Exit taxes represent an expression of state’s sovereignty by taxing value increases of assets, hidden reserves and any untaxed income that arose on its territory. These taxes are triggered before the state of emigration loses its power of taxation as a result of the transfer to the jurisdiction of another state when an individual or company changes residency. READ MORE