Essays about: "uniform taxation"
Showing result 6 - 10 of 11 essays containing the words uniform taxation.
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6. Per Aspera Ad Astra: Towards the International Fiscal Meaning of the Concept 'Beneficial Owner'
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The term ‘beneficial owner’ was first internationally introduced by the OECD in the Model Convention in 1977 and since that time it serves as one of the anti-abuse rules directly provided for in double tax treaties. The concept is critical for determining the eligibility of a person for the tax treaty benefits and for the allocation of taxing rights between two contracting states with regard to dividends, interest or royalties income. READ MORE
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7. Transfer Pricing Profit Split Methods : A Practical Solution?
University essay from IHH, RättsvetenskapAbstract : The purpose of this master’s thesis is to explain and analyze whether today’s existing regulations provide sufficient guidance on how to apply the Profit Split Method (PSM) in practice. Since the enterprises’ profits arising from intra-group transactions increases, the tax base for any government also becomes larger and more important. READ MORE
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8. The Global Effect of the Glaxo Case : The Increase of Transfer Pricing Conflicts between the OECD and the US
University essay from IHH, RättsvetenskapAbstract : This master’s thesis compares the OECD transfer pricing recommendations with the transfer pricing rules of the US. The main focus is the ethical pharmaceutical industry and intangible property, in particular marketing intangibles. READ MORE
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9. Will the SE Incentive the Process of Harmonization or Determine the Opposite Outcome?
University essay from Lunds universitet/Juridiska institutionenAbstract : In the beginning of the October 2004 a new legal entity made its debut in the European Community system: the SE or Societas Europaea. The content of the regulation introducing this corporate form clearly shows how the SE project has been concretised in reality. READ MORE
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10. The Implications of the Arbitration Convention : A step back for the European Community or a step forward for elimination of transfer pricing related double taxation?
University essay from IHH, RättsvetenskapAbstract : It was assumed in the mid 1990s that 60% of all global trade took place within a group of enterprises. With increased globalisation leading to an increase in mergers and acquisitions this figure is most likely higher. Thus intra-company and intra-group transactions form a major part of business. READ MORE
