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3918 Uppsatser om General anti-avoidance rule (GAAR) - Sida 2 av 262
Personaloptionsbestämmelsen : Beskattning av personaloptioner enligt den nya lydelsen efter 1 januari 2009
The swedish rule concerning the treatment of employee stock-options have changed and the new wording of the rule will be applicable for the first time in 2010. The previous wording of the rule stated that the employee shall be taxed for the stock-option when moving abroad, even if the option is not exercised. The Swedish Skatteverket and Regeringsrätten have found that this rule is in conflict with the free movement of persons within the European Union. The new wording of the rule states that the employee shall be taxed when the option is excercised, no matter where the employee is situated. A state`s right of taxation of a stock-option determines wheter and to what extent the employee stock-otion derives from that state..
Beröringsrädsla Om konfliktundvikande i parrelationer
The purpose of this study was to examine experienced family counselors view regarding the concept of conflict avoidance in couple relationships. Twelve family counselors working in different parts of Sweden was interviewed using a semi-structured interview guide. They were asked to reflect on the following: their description of the concept of conflict avoidance, the consequences of conflict avoidance in couple relationship, gender differences and their own view on how to create conditions for constructive, therapeutic work in this respect.The result shows that the fear of conflicts, difficulty in expressing needs, different perceptions and expectations together with a difficulty to negotiate about differences, creates a lack of emotional and physical contact together with an absence of dialogue. The consequences of this in the long-term, a majority of the respondents perceived, are feelings of anger, resignation, powerlessness and unhappiness..
Sexmånadersregelns förenlighet med EU-rätten
The purpose of this thesis was to analyse if the six month rule in chapter 3 § 9 part 1 in IL is compatible with EU law regarding the free movement of employees and in case of discrimination whether the rule can be justified. First of all the retroactive salary for an unlimited taxpayer and during the period of income earning a limited taxpayer who later became unlimited taxpayer will be analyzed in order to determine if they are considered to be in a comparable situation. An unlimited taxpayer is subject to taxation in Sweden for all of his incomes regardless their origin. However there is an exception according to six month rule, which implies that physical persons who stay abroad due to their minimum six months employment are in Sweden free from their incomes earned abroad if they are taxed in the country of employment. Tax exemption is applicable even if the payment from an employee working abroad is made retroactively.Article 18 EUFF states a general prohibition of discrimination on the grounds of nationality.
The Golden Rule and Bioethics. A Reflection upon the Foundation of Ethics
The object of this thesis is the foundation of ethics. The question is whether there exists a universal core to ethics consisting of a fundamental ethical principle across cultures. This principle could for example be the so-called Golden Rule, which goes as follows: ?You should do to others what you want them to do to you?. The Golden Rule is to be found in many of the world?s religions and is also reflected in secular society.
Bilden av det r?da Kina. Mao Zedongs regeringstid i skolans l?romedel i historia 1970-2010
This study investigates the evolution of depictions of Maoist China in Swedish history textbooks from 1970 to 2010. Through examining textbooks from this period, 20 years before the end of the cold war and 20 years after it, this study aims to investigate how quickly and how radically textbooks can change in their depictions of controversial and significant historical periods. Comparing descriptions of both people, tumultuous events, and general trends in China under Mao's rule, this study finds significant differences in how the textbooks describe Maoist China. While textbooks in the 1970s give a largely positive, sympathetic and hopeful view of China, during the 1990s and 2000s that perspective has been overtaken by an overwhelmingly critical view of Mao and his rule, focusing on his failures and dictatorial rule. The findings add to a somewhat divided field of research on the adaptability of textbooks, leaning toward the idea that textbooks can change rapidly during times of turmoil in a society..
Att komma ikapp : notläsning för pianister
EU law is superior to Swedish domestic law, and it is on Sweden's responsibility to implement the COJ judgments so that it becomes compatible with EU law. The advantage of the Union being superior is the internal market given the member states.However, problems arise when the Swedish legislature goes further in its interpretation of EU law. Restrictions can be imposed but it must be considered to be strongly motivated so the restriction outweighs the need to maintain the freedoms granted by EU law. In Cadbury Schweppes, the court states that restrictions on freedom of establishment may be done to counter artificial arrangements whose sole purpose is to evade the national tax. Its further stated that an artificial arrangement does not exist in those cases there is a real business, even through the establishment in the low-taxing country is economically justified. The Swedish CFC rules states that the general rule is that if an establishment in a country within the EEA, which have lower corporate tax than 55% of the Swedish tax, the shareholder of this company is taxed on its current share in Sweden. The outcome of Cadbury Schweppes has not been made into a general rule, it became the exception. In addition to that in Sweden it is presumed that the company is an artificial arrangement that expressly are prohibited by the EUD, as well been implemented to supplement the rule, where the Swedish legislature changes the meaning of the term granted by the appeal. The Swedish legislature has amended the original economically motivated establishment, to be commercially motivated. The term is undefined, but applicable elsewhere in the Incometaxlaw and from this one can find that, for an establishment to be considered as commercially motivated the decisions to establish should be taken to promote normal profit-making enterprises based upon commercially motivated decisions..
Studier av insolvensförordningens artikel 5 : -särskilt om sakrättsbegreppets betydelse för borgenärer med företagshypotek
Bullying is today a major problem in schools worldwide. Far too many children are forced to undergo bullying day in and day out without anyone seeing or doing something. My purpose with this study is to find out how four F-6 schools in a municipality south of Stockholm are describes their work to get zero tolerance for bullying at their school.My questions are:How does the four F-6 schools' anti-bullying group in a municipality south of Stockholm describes their work to have zero tolerance for bullying?What do the employees in the school anti-bullying groups consider that bullying is?Why do the employees in the school anti-bullying groups think bullying occurs?Who do the employees in the school anti-bullying groups think are bullies or are being bullied?To get my results I have done four interviews with those in charge of the school's anti-bullying group. My theory is based on standards, what is acceptable behavior and normative theory, hypotheses, what is right and wrong as well as desirable or undesirable behavior.
Manlig omskärelse : Föräldrarnas eller barnets religionsfrihet?
Bullying is today a major problem in schools worldwide. Far too many children are forced to undergo bullying day in and day out without anyone seeing or doing something. My purpose with this study is to find out how four F-6 schools in a municipality south of Stockholm are describes their work to get zero tolerance for bullying at their school.My questions are:How does the four F-6 schools' anti-bullying group in a municipality south of Stockholm describes their work to have zero tolerance for bullying?What do the employees in the school anti-bullying groups consider that bullying is?Why do the employees in the school anti-bullying groups think bullying occurs?Who do the employees in the school anti-bullying groups think are bullies or are being bullied?To get my results I have done four interviews with those in charge of the school's anti-bullying group. My theory is based on standards, what is acceptable behavior and normative theory, hypotheses, what is right and wrong as well as desirable or undesirable behavior.
Bolag i skatteparadis : Affärsmässigt motiverad verksamhet eller skatteflykt i form av konstlade upplägg
EU law is superior to Swedish domestic law, and it is on Sweden's responsibility to implement the COJ judgments so that it becomes compatible with EU law. The advantage of the Union being superior is the internal market given the member states.However, problems arise when the Swedish legislature goes further in its interpretation of EU law. Restrictions can be imposed but it must be considered to be strongly motivated so the restriction outweighs the need to maintain the freedoms granted by EU law. In Cadbury Schweppes, the court states that restrictions on freedom of establishment may be done to counter artificial arrangements whose sole purpose is to evade the national tax. Its further stated that an artificial arrangement does not exist in those cases there is a real business, even through the establishment in the low-taxing country is economically justified. The Swedish CFC rules states that the general rule is that if an establishment in a country within the EEA, which have lower corporate tax than 55% of the Swedish tax, the shareholder of this company is taxed on its current share in Sweden. The outcome of Cadbury Schweppes has not been made into a general rule, it became the exception. In addition to that in Sweden it is presumed that the company is an artificial arrangement that expressly are prohibited by the EUD, as well been implemented to supplement the rule, where the Swedish legislature changes the meaning of the term granted by the appeal. The Swedish legislature has amended the original economically motivated establishment, to be commercially motivated. The term is undefined, but applicable elsewhere in the Incometaxlaw and from this one can find that, for an establishment to be considered as commercially motivated the decisions to establish should be taken to promote normal profit-making enterprises based upon commercially motivated decisions..
Optimering av sampling quality-parametrar för Mental Ray
Fotorealistiska 3d-bilder används idag inom ett brett spektrum av branscher. Framställningen av denna typ av grafik kräver ofta väldigt mycket datorkraft. Vid rendering med renderingsmotorer som använder sig av raytracing algoritmer är aliasing ett medfött problem. Lösningen heter anti-aliasing som arbetar för att undvika aliasing artefakter som jagged edges eller Moiré-effekter med mera. En del av anti-aliasingprocessen är supersampling som ofta kräver mycket datorkraft.
Utomståenderegeln i 57:5 IL
AbstractThis bachelor thesis deals with the close company rules in chapter 56-57 within the Swedish income tax law (IL). The purpose of this thesis is to analyse the outsider rule in 57:5 IL. If a shareholder or a family member works or have worked actively within the company within the fiscal year or the last five fiscal years then the partner has qualified shares and is to be taxed according to the special closed company rules.If an outsider, directly or indirectly, is a significant shareholder within the company, and directly or indirectly, are entitled to dividends then an active partner only has qualified shares if there is special reasons. When making the assessment regard must be made to conditions under the fiscal year or the last five fiscal years. There is special reason not to apply the rule if there are agreements regarding how the profit should be split or cross-ownerships between companies.If a taxpayer can show that an outsider own 30 percent of the closed company and has a right to dividends and there is no special reason to why the rule should not be applied then the outsider rule is applicable.
Tredjemanskontroll - Säker rätt är säkert rättssäker : En studie med utgångspunkt i betänkandet Förbudet mot dubbla förfaranden och andra rättssäkerhetsfrågor i skatteförfarandet (SOU 2013:62)
SKV and Tullverket have several important tools and methods available in each activity to ensure that taxes and fees are paid and charged rightfully. Among other things they use tax or customs surcharges, targeted and general third party injunctions or targeted and general third party audits. The targeted controls, ergo targeted injunctions and audits, are targeted towards specific persons or documents while during the general controls these are not specified. The methods have repeatedly been the subject of discussions and attempts to simplify the tax procedure and increase the Rule of Law for the individual.The government appointed a commission on March 8 of the year 2012 with the assignment to prepare proposals to increase the Rule of Law in the tax procedure. The assignment was therefore to analyze the areas of tax and customs injunctions, reimbursement because of expenses and agents and also third party controls.
Sverigedemokraterna i Ronneby : Teorikonsumerande studie med fallet i centrum
With varied electoral success for anti-immigration parties across Western Europe, Sweden is often held as an example where anti-immigration parties have been less successful. This have caught the interest of many scientists around the world and have recently developed theories on a subnational level when testing Sweden?s municipalities, on why they have failed here but not in other countries. But in the election to 2010, Sweden now joins the rest of the Western-European countries in having an anti-immigrations party in the parliament.This paper has tested three theories on a Municipality that has shown evident support for the Sweden democrats, both in the local and the national election. This is done with a qualitative approach, made up from interviews with the local established parties.
Mobbning bland barn i skolan : Hur fyra F-6 skolors antimobbningsgrupper beskriver sitt arbete för att få nolltolerans mot mobbning
Bullying is today a major problem in schools worldwide. Far too many children are forced to undergo bullying day in and day out without anyone seeing or doing something. My purpose with this study is to find out how four F-6 schools in a municipality south of Stockholm are describes their work to get zero tolerance for bullying at their school.My questions are:How does the four F-6 schools' anti-bullying group in a municipality south of Stockholm describes their work to have zero tolerance for bullying?What do the employees in the school anti-bullying groups consider that bullying is?Why do the employees in the school anti-bullying groups think bullying occurs?Who do the employees in the school anti-bullying groups think are bullies or are being bullied?To get my results I have done four interviews with those in charge of the school's anti-bullying group. My theory is based on standards, what is acceptable behavior and normative theory, hypotheses, what is right and wrong as well as desirable or undesirable behavior.
Arbetet inom skolan för att förebygga mobbning
My purpose in this work was to find out how staff in a middle sized school uses its local Equal treatment plan in its work against bullying. But also to see how the use of a standardized anti-bullying program works to prevent bullying. I have interviewed the principal, teachers, and what we in Sweden call a ?fritidspedagog? and the members of the anti-bullying team to get answers to my questions. The conclusion of this study is that the school follow and work according to what the Equal treatment plan states, both in terms of prevention, as in working with actual bullying cases. The school has also followed the National School Agency's recommendations on what should be the local Equality plan, but also to follow up and revise it each year. The interview shows that the staff at the school placed great emphasis on talking and discussing with students about how to behave towards each other, they also brought up things that happened at one time and talked about this. The staffs were very committed to work towards the prevention of bullying and the same was true with the school's headmaster.