Advanced search
Showing result 16 - 20 of 56 essays matching the above criteria.
-
16. Hard to value intangibles from a Swedish perspective
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The purpose of this thesis is to study the work of the OECD presented in the Final BEPS-Report under Action 8 concerning hard to value intangibles in a Swedish context. Further, the OECD Model Tax Convention and its Commentaries are discussed in terms of their validity as a source of law in a Swedish perspective, or if there is a requirement now or after the implementation of Action 8 for changes to the Inkomstskattelagen, and particular the Korrigeringsregeln. READ MORE
-
17. Impact and Adoption of Flexibility in a Rigid and Centralized Distribution Network : A Case Study on a Global Manufacturing Company
University essay from KTH/Industriell ManagementAbstract : For manufacturing firms to succeed in the global marketplace it is important that they have an efficient supply chain that is well adapted to the characteristics of the products. This thesis explore the companies' challenge to adapt its supply chain to the characteristics of heir products. READ MORE
-
18. How can the proposed changes to the OECD tax model convention in action 1 and action 7 counter the issue of an artificial avoidance of a PE status?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The purpose of this thesis is to clarify how, according to BEPS action 1 and action 7, can the amendments of the “specific activity exemptions” in article 5 paragraph 4 of the OECD Model Tax Convention on Income and Capital (the model convention) counter the issue of an artificial avoidance of a PE status. The main issues that are connected to the concept of a permanent establishment are artificial avoidance of the status of a permanent establishment, the use of transfer pricing rules in order to artificially allocate the profits of a permanent establishment to low tax states and finally that some enterprises that operate within the digital economy can avoid the status of a permanent establishment due to the lack of physical presence. READ MORE
-
19. Transfer Pricing Treatment of Transactions with Hard-to-Value Intangibles: Is BEPS Action 8 Based on the Arm’s Length Principle?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This master’s thesis analyses BEPS Action 8 recommendations in relation to transactions with hard-to-value intangibles. OECD has developed them with a view to ensure that transfer pricing outcomes of transactions with hard-to-value intangibles are aligned with value creation. READ MORE
-
20. BEPS Action plan 13 in the light of confidentiality
University essay from Lunds universitet/Institutionen för handelsrättAbstract : OECD introduced 15 Action plans as part of the BEPS-project in 2014 in their work to combat base erosion and profit shifting (BEPS). Action plan 13 provides for a re-examined transfer pricing documentation and a new Country-by-country-reporting. The CbC-reporting is to be included in a three-tired approach including a master-file and a local-file. READ MORE
