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Showing result 1 - 5 of 36 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. Is control over risk getting out of control? : An analysis of the concept of control over risk as set out in the 2022 OECD Guidelines in relation to Swedish law

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Karolina Linusson; [2023]
    Keywords : control over risk; OECD Transfer Pricing Guidelines; transfer pricing; the arm s length principle; kontroll över risk; internprissättning; armlängdsprincipen;

    Abstract : In 2017 an amended version of the OECD Transfer Pricing Guidelines was published which included new provisions to prevent BEPS through the shifting of risks. Through the amendment of the Guidelines, it was clarified that for an entity in an MNE to contractually assume a risk, for transfer pricing purposes, it needs to control the risk and have the financial capacity to assume it. READ MORE

  4. 3. The Grey Area of Taxation - An essay on Low Value-Adding Services in Swedish Tax Law

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

    Author : Douglas Linton Wahlgren; [2023]
    Keywords : skatterätt; finansrätt; koncerninterna tjänster; internprissättning; vinstallokering; Law and Political Science;

    Abstract : This essay critically examines the legal aspects of low value-adding services within multinational corporations, focusing on their treatment in Swedish tax law and the OECD Transfer Pricing Guidelines (OECD TPG). It explores the challenges and complexities involved in defining and taxing intragroup services, emphasizing their impact on profit shifting strategies. READ MORE

  5. 4. Unlawful State Aid Through Tax Rulings : The use of an arm’s length principle to evaluate selective advantage in Art. 107.1 of the Treaty on the Functioning of the European Union

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Måns Widstrand; [2022]
    Keywords : ;

    Abstract : .... READ MORE

  6. 5. 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