Sökning: "Anti-Tax Avoidance Directive Proposal"

Hittade 3 uppsatser innehållade orden Anti-Tax Avoidance Directive Proposal.

1. 1. Does the deferred payment method of Art. 5 ATAD provide for a technique proportionate to mitigate liquidity disadvantages of exit taxes?

   Magister-uppsats, Lunds universitet/Institutionen för handelsrätt

   Författare :Sven Uetermeyer; [2021]
   Nyckelord :exit tax; exit taxation; ATAD; tax avoidance; deferred payment; deferral; liquidity disadvantage; Law and Political Science;

   Sammanfattning : This thesis analyses the deferred payment method of Art. 5 para. 2 ATAD. It asks whether or not it is proportionate to mitigate liquidity disadvantages stemming from exit taxes. LÄS MER

3. 2. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?

   Magister-uppsats, Lunds universitet/Institutionen för handelsrätt

   Författare :Margret Agusta Sigurdardottir; [2016]
   Nyckelord :Tax; Taxation; Tax Law; Direct Taxation; Fundamental Freedoms; Double Taxation; Double Non-Taxation; Tax Avoidance; Aggressive Tax Planning; The Single Tax Principle; Single Taxation; Tax Treaty Law; GAAR; General Anti-Abuse Rule; Exemption Method; Credit Method; Dividend; Interest; Classification of Income; International Tax Regime; ECJ Case Law; Hybrid Mismatch Arrangements; Hybrid Financial Instruments; Parent-Subsidiary Directive; Base Erosion and Profit Shifting; BEPS; BEPS Action Plan 2; Anti-Hybrid Rules; Linking Rules; Correspondence Principle; Anti-Tax Avoidance Directive Proposal; Parent-Subsidiary Directive Amendments; Justification Grounds; EU Law; Law and Political Science;

   Sammanfattning : The purpose of the thesis is to analyse the problems of hybrid mismatch arrangements within the EU and how single taxation, which requires income to be taxed once, not more or less, can be secured under EU law. After the amendments of the Parent-Subsidiary Directive (PSD), where an anti-hybrid rule was enacted, the legal environment for companies within the European Union changed. LÄS MER

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

   Magister-uppsats, Lunds universitet/Institutionen för handelsrätt

   Författare :Latifa Omri; [2016]
   Nyckelord :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;

   Sammanfattning : 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. LÄS MER