Essays about: "treaty override"
Showing result 1 - 5 of 8 essays containing the words treaty override.
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1. BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty - Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The thesis provides an overview of the relationship between tax treaties and domestic law and issues that arise if a contracting state uses domestic anti-avoidance rules to prevent the improper use of a tax treaty. Improper use of a tax treaty is an issue addressed in the BEPS Action 6 report. READ MORE
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2. Treaty Override in German Domestic Law - In Line with the Constitution?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The German Federal Fiscal Court has in its decision from the 11th of December 2013 announced doubts of the constitutionality of a German national provision, including a treaty override, with the Constitution. This paper is aimed at shedding some light on the reasons for this decision, to give an outlook on the still pending decision of the highest German constituional court and to name influences on other countries. READ MORE
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3. Exit Taxation in the European Union, Is there really a problem?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Exit taxes represent an expression of state’s sovereignty by taxing value increases of assets, hidden reserves and any untaxed income that arose on its territory. These taxes are triggered before the state of emigration loses its power of taxation as a result of the transfer to the jurisdiction of another state when an individual or company changes residency. READ MORE
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4. Potential double tax treaty override of South African exit taxation law – how do tax treaties allocate the right to tax unrealized gains?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : South African income tax legislation makes provision for the levying of exit taxes or charges when individuals emigrate from or companies cease to be residents or become headquarter companies, or when controlled foreign companies (CFC) cease to be CFCs otherwise than by way of becoming residents. As indicated by the title the discourse followed in this paper entails the analysis of treaties to ascertain the connecting factors employed by the OECD Model treaty giving rise to signatories levying exit taxes. READ MORE
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5. Is A New International Law On E-book ‘Lending’ Necessary To Satisfy The Requirements of International Human Rights Law?
University essay from Lunds universitet/Juridiska institutionenAbstract : In the last few years there has been a huge growth in the e-book market, and many copyrighted works are published as e-books before the analogue versions are printed, if they are ever printed. In order to provide e-book lending services, libraries must sign copious amounts of license agreements with materials distributors. READ MORE
