Essays about: "underkapitalisering"

Found 1 essay containing the word underkapitalisering.

  1. 1. Thin Capitalisation : A comparison of the application of article 9.1of the OECD model tax convention and the Swedish adjustment rule to thin capitalisation

    University essay from IHH, Rättsvetenskap

    Author : Magnus Eriksson; Fredrik Richter; [2006]
    Keywords : transfer pricing; thin capitalisation; mobil oil; arm s length principle; internprissättning; underkapitalisering; mobil oil; armlängdsprincipen;

    Abstract : This thesis answers the question “How does the application of the Swedish adjustment rule correspond to the OECD point of view regarding intragroup loans to thinly capitalised companies?” The question is answered by using the traditional legal method and by examining the way the adjustment rule is applied by the Supreme Administrative Court, the Swedish approach when using the arm’s length principle in Swedish law is then compared to the approach recommended by the OECD. From a tax point of view intragroup prices on commodities and services are of vital importance for multinational enterprises, since these prices in the end affects the total corporate taxation. READ MORE