Search for dissertations about: "Bertil Wiman"

Found 2 swedish dissertations containing the words Bertil Wiman.

2. 1. Compensation of Losses in Foreign Subsidiaries within the EU : A Comparative Study of the Unilateral Loss-Compensation Mechanisms in Austria and Denmark

   Author : Anna Gerson; Björn Westberg; Niels Winther-Sørensen; Bertil Wiman; Jönköping University; []
   Keywords : SAMHÄLLSVETENSKAP; SOCIAL SCIENCES; SAMHÄLLSVETENSKAP; SOCIAL SCIENCES; Losses; group taxation; loss relief; neutrality; single-entity approach; horizontal equity; ability to pay principle; double dip; arbitrary income shifting; permanent income shifting; Financial law; Finansrätt; European law; EU-rätt;

   Abstract : This study commences in the problems related to the restricted possibilities for cross-border groups to take losses incurred in foreign subsidiaries into account upon taxation. These difficulties lead to the situation where the overall tax burden of the group, seen as an economic unit, might exceed its economic capacity. READ MORE

4. 2. Permanent Establishment through Related Persons : A Study on the Treatment of Related Persons under Article 5 of the OECD Model Tax Convention

   Author : Linus Jacobsson; Mattias Dahlberg; Bertil Wiman; Mar­jaana Helminen; Uppsala universitet; []
   Keywords : SAMHÄLLSVETENSKAP; SOCIAL SCIENCES; PE; permanent establishment; taxation; international taxation; tax treaty; OECD MTC; Article 5; related person; related company; related enterprise; BEPS; Finansrätt; Fiscal Law;

   Abstract : Globalization, changed business practices and the developments in information technology have put pressure on the PE concept. This thesis deals with related persons and the PE concept, and the increasing tension between them.The main objective of the thesis is to analyze and define the scope of the PE concept, when applied to related persons. READ MORE