Sökning: "Allocation of taxing rights"
Visar resultat 1 - 5 av 15 uppsatser innehållade orden Allocation of taxing rights.
1. The digital economy and its implications: does the OECD’s Pillar One Proposal challenge the principles of law within International and EU tax law?
Magister-uppsats, Lunds universitet/Institutionen för handelsrättSammanfattning : Change is the only constant; yet, as we step into the brave new world of taxing the digital economy, it might seem like the need and development of principles and rules for adequate profit allocation has only begun. This thesis discusses the profit allocation rules under the Unified Approach of the OECD Pillar One Proposal Amount A in relation to three identified principles of law in international and European tax law. LÄS MER
2. EU-förenliga riktade ränteavdragsbegränsningar – en möjlig realitet eller fantasi
Uppsats för yrkesexamina på avancerad nivå, Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenSammanfattning : The right to deduct interest expenses is limited by the general and targeted interest deduction limitation rules, including the “exemption rule” in Chapter 24, Paragraph 18, subparagraph 2 of the Law on income tax. This rule excludes the right to deduct interest paid on intra-group loans if such loans have been made exclusively or almost exclusively for the purpose of obtaining a substantial tax benefit for the group. LÄS MER
3. The Distribution Tax Regime Paradox - Compatibility of Estonian Tax Treatment of Non-Residents’ Capital Gains from Alienation of Immovable Property with European Law
Magister-uppsats, Lunds universitet/Institutionen för handelsrättSammanfattning : The four fundamental freedoms granted to residents in the Community have become the pillars for fairness between economic operators and persons within the internal market. The aim of the freedoms is to prohibit any restriction or discrimination toward residents of another Member State and endorse equal treatment. LÄS MER
4. Whether nexus rules under EU Commission proposal of Significant digital presence rules is compatible with separate provisions of international tax law
Magister-uppsats, Lunds universitet/Institutionen för handelsrättSammanfattning : Growing digitalisation of the global economy is brining irreversible changes in business models and structure of economic relationships. External factors, such as pandemiс, only facilitate the process of remote participation in economic life and performing economic functions. LÄS MER
5. Allocation of Taxing Rights of Occupational Pension in Cross-Border Situations between an ETT- and EET- or TET-system : An Analysis between Sweden and Portugal
Magister-uppsats, Uppsala universitet/Juridiska institutionenSammanfattning : The fact that pension consists of three cashflows that can be taxed at different points in time has resulted in a great divergence in how states treat the income of pension. Nonetheless, a majority of tax treaties allocate the exclusive taxing rights of private occupational pension to the residence state as advocated by the Organisation for Economic Co-operation and Development. LÄS MER
