Essays about: "the arm s length principle"

Showing result 1 - 5 of 30 essays containing the words the arm s length principle.

  1. 1. Addressing Aggressive Tax Planning through Unitary Tax or Self-Regulation- A Study on the Possible Need for an International Tax Reform

    University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

    Author : Astrid Bendixen Kettis; [2020]
    Keywords : International Tax Law; Corporate Taxation; CSR; Law and Political Science;

    Abstract : Domestic and international regulations aiming to facilitate international trade and investment today enable multinational corporations (MNCs) to operate transnationally through the use of branches or subsidiary companies. Within the field of corporate taxation, the lack of a global and universal tax system regulating international tax matters however allows MNCs to exploit gaps and loopholes within such regulations to lower or even eradicate their tax burden. READ MORE

  2. 2. The Commission’s Approach in State Aid Assessment of Advance Pricing Agreements: an Autonomous EU Arm’s Length Principle and Its Implications

    University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

    Author : Polina Parshina; [2020]
    Keywords : Law and Political Science;

    Abstract : This thesis aims to reveal whether the Commission’s approach in the State aid assessment of advance pricing agreements (APAs) is in line with the current EU law framework and whether, given its implications, it is a sensible development in State aid law applied to taxation. Chapter 2 introduces the background of the arm's length principle, looking into its origin, purpose and application in tax law. READ MORE

  3. 3. Can the Arm’s Length Principle in the OECD Transfer Pricing Guidelines Fulfil the Minimum Requirements of the Transaction Approach in the Controlled Foreign Company Rules under Anti-Tax Avoidance Directive?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Zhijie Qiu; [2019]
    Keywords : Arm s Length Principle; CFC Rules; ATAD; BEPS; Law and Political Science;

    Abstract : Generally, the ALP in TP regulations is widely applied in order to prevent price manipulation which will cause tax avoidance. And CFC regulations have usually been regarded as a “backstop” of TP regulations in terms of combating tax avoidance. READ MORE

  4. 4. The Seeking of a Business-Optimal Transfer Price - In accordance with the Arm's Length Principle

    University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

    Author : Oskar Paladini Söderberg; [2019]
    Keywords : Transfer pricing; game theory; skatterätt; international taxation law; Arm s length principle; Law and Political Science;

    Abstract : The search of a business-optimal transfer price has been going on for decades. One interesting solution aimed to, by the use of game theory, bargaining theory and transfer pricing, create a quantitative solution to optimize the global profits of a multinational enterprise. READ MORE

  5. 5. Fiscal Sovereignty and State Aid in the field of Direct Taxation of EU Law

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Kristina Lyrenäs; [2019]
    Keywords : State aid; EU Commission; Apple; Starbucks; Fiat; Amazon; Engie; Belgian excess profit regime; fiscal sovereignty; Law and Political Science;

    Abstract : This thesis investigates if the recent decisions by the Commission on State aid in direct tax law are intruding on the EU Member States’ fiscal sovereignty. The author concludes that the Commission’s basic legal arguments of the reference system, being the corporate income tax system of the relevant Member States, as well as the arm’s length principle as a tool to assess selectivity in article 107(1) TFEU, are problematic from a fiscal sovereignty point of view. READ MORE