Search for dissertations about: "Tax neutrality"

Showing result 1 - 5 of 12 swedish dissertations containing the words Tax neutrality.

  2. 1. Methods for Elimination of Double Taxation under Double Tax Treaties – with Particular Reference to the Application of Double Tax Treaties in Sweden

    Author : David Kleist; Göteborgs universitet; []
    Keywords : SAMHÄLLSVETENSKAP; SOCIAL SCIENCES; double taxation; double tax treaty; capital export neutrality; CEN; CIN; capital import neutrality; exemption; exemption with progression; modified exemption; limitation of the tax rate; credit; full credit; ordinary credit; tax sparing credit; foreign tax credit limitation; maximum deduction; interpretation of double tax treaties; model tax convention on income and on capital; the OECD Model; the Commentaries of the OECD Model; subject identity; timing mismatch; attribution of income; allocation of expense; RÅ 1996 ref. 84; RÅ 2008 ref. 24; RÅ 2010 ref. 112; dubbelbeskattning; dubbelbeskattningsavtal; skatteavtal; kapitalexportneutralitet; kapitalimportneutralitet; alternativ exempt; OECD:s modellavtal;

    Abstract : Kleist, D. 2012. Methods for Elimination of Double Taxation under Double Tax Treaties – with Particular Reference to the Application of Double Tax Treaties in Sweden. Iustus Förlag AB. READ MORE

  4. 2. Corporate form and international taxation of box corporations

    Author : Roland Dahlman; Peter Melz; Mats Tjernberg; Stockholms universitet; []
    Keywords : SAMHÄLLSVETENSKAP; SOCIAL SCIENCES; International taxation; tax theory; corporations; treaties; group indirect ownership; tax planning; neutrality; exchange of information; Financial law; Finansrätt;

    Abstract : The subject matter of the thesis is new as the phenomenon of the Box Corporation has not been the subject of a specialized investigation from the fiscal perspective before. A foreign subsidiary indirectly owned in a third country jurisdiction is in the thesis classified as a Box Corporation. READ MORE

  5. 3. Cross-Border Consumption Taxation of Digital Supplies : A Comparative Study of Double Taxation and Unintentional Non-Taxation of B2C E-Commerce

    Author : Pernilla Rendahl; Björn Westberg; Christina Moëll; Ole Gjems-Onstad; Jönköping University; []
    Keywords : SAMHÄLLSVETENSKAP; SOCIAL SCIENCES; SAMHÄLLSVETENSKAP; SOCIAL SCIENCES; LAW JURISPRUDENCE; RÄTTSVETENSKAP JURIDIK;

    Abstract : Consumption taxes such as a value added tax (VAT) or a goods and services tax (GST) is an important revenue source for several countries, not least within the European Union (EU) which has had a harmonized VAT since the end of the 1960s. The intention of consumption taxation is to tax expenditures made by persons for their private purposes, i.e. READ MORE

  6. 4. 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

  7. 5. Hybrid Mismatches in International Transactions : A Study of Linking Rules in EU and Tax Treaty Law

    Author : Autilia Arfwidsson; Martin Berglund; Claes Norberg; Jesper Johansson; Uppsala universitet; []
    Keywords : SAMHÄLLSVETENSKAP; SOCIAL SCIENCES; hybrid mismatch; linking rules; hybrid mismatches; hybrid mismatch rules; taxation; international taxation; tax treaty; OECD MTC; BEPS; EU law; ATAD; Finansrätt; Fiscal Law;

    Abstract : Hybrid mismatches, where differences in income characterisation across jurisdictions lead to double non-taxation, can be exploited by multinational enterprises to reduce their overall tax burden. Common hybrid mismatch rules addressing this issue have recently been introduced within the EU and the OECD. READ MORE