Essays about: "territorial tax system"

Found 4 essays containing the words territorial tax system.

  1. 1. Tangible Intangibles in the United States’ Tax Cuts and Jobs Act : How Mixed Definitions of “Intangible” Lead to Mixed Results in the United States’ Efforts to Close Tax Loopholes, Move to a Territorial Tax System, and Reduce Base Erosion and Profit Shifting Abuses

    University essay from Uppsala universitet/Juridiska institutionen

    Author : James Summers; [2018]
    Keywords : tax; law; international tax law; intangible; tangible; property; income; definition; territorial tax system; worldwide tax system; OECD; WTO; United States; TCJA;

    Abstract : The United States’ Tax Cuts and Jobs Act of 2017 (TCJA) changed a 30-year-old definition of the term “intangible property” and added assessment requirements for two different types of “intangible income”, both of which deviate from the newly changed general definition of “intangible” and most common understandings of the meaning of the word.  While it may appear unlikely that a change in meaning of a single word in a large tax code could have a drastic effect on international taxation, the differing definitions of “intangible” create far-reaching tangible consequences. READ MORE

  2. 2. Cross-border Loss Utilization Concerning the Tax Treatment of a Taxpayer’s Own Losses Attributable to a Permanent Establishment in Relation to the Territoriality Principle –From an International and EU law Perspective

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Rebecca Hägg; [2015]
    Keywords : Cross-border; Permanent Establishment; Double Tax Convention; the Territoriality Principle; Losses; Exemption Method; Loss Utilization; Law and Political Science; Business and Economics;

    Abstract : The European Commission has acknowledged the lack of cross-border utilization of losses. Companies operating internationally want to have a possibility to offset losses against taxable profits at the same time or as soon as possible after the losses incurred. READ MORE

  3. 3. Taxation : a critical discussion of the present tax system in Kosovo

    University essay from Linnéuniversitetet/Ekonomihögskolan, ELNU

    Author : Egzona Gash; [2011]
    Keywords : Tax- policy; efficiency; allocation; transition; base; reform;

    Abstract : Abstract Title: Taxation - A critical discussion of the present tax system in Kosovo Institution: School of Business and Economics University: Linnaeus University Aim: The aim of this thesis is to characterize and critically discuss thepresent tax system in Kosovo, keeping in mind the fundamentalproblems presented in weak tax bases, informal economies, ethniccontroversy and limited inflow of FDI in the country. Further,contributing with alternative designs of the tax system and argueadvantages and disadvantages of these designs Method: The thesis will attempt to relate the descriptions and analysis of the taxsystem in existing and essentially established theory. READ MORE

  4. 4. Formulary Apportionment in the European Union

    University essay from Lunds universitet/Juridiska institutionen

    Author : Aisha Butt; [2005]
    Keywords : EG-rätt; Skatterätt; Law and Political Science;

    Abstract : The European Union has discussed the idea of a potential shift from a system of dividing the EU source income of multinational companies based on separate accounting and the arm's length principle, to one based on consolidated base taxation with formulary apportionment. EU businesses have for several years highlighted numerous tax obstacles in the EU that prevent them from operating on the basis consistent with the Single Market. READ MORE