Essays about: "thin capitalization"

Found 5 essays containing the words thin capitalization.

  1. 1. Thin Capitalization in the OECD, the EU and Sweden: policy responses, evaluation and alternatives.

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

    Author : Sotirios Apostolou; [2018]
    Keywords : Tax law; OECD; BEPS; BEPS Action 4; EU; ATAD; Thin Capitalization; debt bias; tax planning; tax shield; interest deduction; interest deduction limitation; interest deduction limitation rule; EBITDA; CBIT; ACE; ACC; COCA; AGI; Law and Political Science;

    Abstract : The issue of thin capitalization has risen in importance in recent years, to the point that it warranted international action. That action came in the form of Action 4 of the OECD BEPS Project, of Article 4 of the EU ATAD and of the new interest deduction limitation rules in the national Swedish legislation. READ MORE

  2. 2. Limitations on interest deductions: does BEPS action 4 presume tax avoidance?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Latifa Omri; [2016]
    Keywords : Interest; limitations; deductions; BEPS; action 4; tax avoidance; presumption; international tax law; EU law; CJEU; thin capitalization; thin cap rules; anti-tax avoidance; fixed ratio rule; group ratio rule; the best practice approach; fundamental freedoms; case law.; Law and Political Science;

    Abstract : Debt and equity are in most countries treated differently for taxing purposes. The asymmetry between the financing forms are being taken advantage of by MNEs, allowing them to plan their cross-border activities in a way that lowers the taxable burden for the whole group. READ MORE

  3. 3. Thin Cap and Iceland - What can happen in the absence of thin capitalization rules?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Jón Bjarni Steinsson; [2013]
    Keywords : Thin capitalization; Interest deduction limitations rules; tax avoidance; tax planning; Iceland; Germany; Denmark.; Law and Political Science;

    Abstract : An examination of how thin capitalization of companies works, rules put in place to counter such behaviour, their affects and how or if such rules might help in a situation in Iceland where multinational corporations seem to be taking an advantage of such rules to avoid paying any income tax.... READ MORE

  4. 4. Interest Deduction Limitation Rules in Sweden and Germany - A Comparison Regarding EU Law Compatibility and Appropriateness

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Enken Cohrs; [2013]
    Keywords : Interest Deduction Limitation; Thin Capitalization; Germany; Sweden; ECJ; EU Law; Ränteavdragsbegränsnigsreglerna; Zinsschranke; Law and Political Science;

    Abstract : The paper deals with the different approaches to limit the deductibility of interest expenses in Sweden and Germany. The rules are analysed in the framework of EU law regarding their compatibility and appropriateness... READ MORE

  5. 5. Thin capitalisation- compatible with EC law?

    University essay from Lunds universitet/Juridiska institutionen

    Author : Khatereh Razazi; [2008]
    Keywords : Skatterätt; Law and Political Science;

    Abstract : Thin capitalization means an abnormally high debt-to-equity ratio of a corporation, in a situation where the debt finance comes from a foreign affiliated contributor of capital. The contributor of debt capital is often simultaneously a direct shareholder. READ MORE