Sökning: "Group Ratio Rule"
Hittade 4 uppsatser innehållade orden Group Ratio Rule.
1. Den generella ränteavdragsbegränsningsregeln - I ljuset av den skatterättsliga neutralitetsprincipenKandidat-uppsats, Lunds universitet/Institutionen för handelsrätt
Sammanfattning : On January 1 2019, extensive changes were introduced to the Swedish corporate tax system. From previously only limiting deductions for interest expenses related to internal loans, the corporate tax reform entails that all interest expenses are limited and all Swedish companies are subject to the regulations. LÄS MER
- Magister-uppsats, Lunds universitet/Institutionen för handelsrätt
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
- L3-uppsats, SLU/Southern Swedish Forest Research Centre
Sammanfattning : This work is a part of international research that was carried out in Latvia, Lithuania and Poland, in order to investigate policy drivers behind the harvesting level in these countries. This thesis was focused on Lithuania. LÄS MER
4. Thin Capitalisation : A comparison of the application of article 9.1of the OECD model tax convention and the Swedish adjustment rule to thin capitalisationMagister-uppsats, Högskolan i Jönköping/IHH, Rättsvetenskap; Högskolan i Jönköping/IHH, Rättsvetenskap
Sammanfattning : 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. LÄS MER