Sökning: "double dip phenomenon"

Hittade 1 uppsats innehållade orden double dip phenomenon.

  1. 1. Assessment of "Anti-Hybrid" Approach to the Problem of Aggressive Tax Planning in the light of the European Commission’s proposal to amend Article 4(1)(a) of the Parent-Subsidiary Directive

    Magister-uppsats, Lunds universitet/Institutionen för handelsrätt

    Författare :Nataliya Strelnikova; [2014]
    Nyckelord :Interest and Royalties Directive; Parent-Subsidiary Directive; switch-over clause; OECD Model; double dip phenomenon; aggressive tax planning; mismatch arrangements; legal pluralism; conflict of classification; hybrid financial instruments; profit distribution; autonomous definition; freedom of establishment; abuse of law; Law and Political Science;

    Sammanfattning : Hybrid mismatch arrangements, which exploit differences in the tax treatment of dividends and interest as well as differences in the classification of financial instruments between two or more countries, have been found to be a widely used tool in aggressive tax planning since multinational companies using hybrid financial instruments could benefit from the “double dip” phenomenon. This issue has been in the spotlight on different levels. LÄS MER