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880 Uppsatser om Harmonization of direct taxation within EU - Sida 3 av 59
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.
Ränteavdrag i företagssektorn : - Skatteverkets förslag till förändring
In Sweden the main principle is that interest expenses are deductable. The rules of limitations on interest deduction are exemptions to this main principle. The provisions, which came into force on the first of January 2009, have been inserted into Chapter 24 secs. 10 a ? e Swedish Income Tax Act (ITA).
Vilande Bolag : Beskattning av fåmansföretag
Title: Dormant companies ? Taxation of closely held companiesProblem: Many companies are facing a business transfer and fall within a smaller company with a few owners and therefore that tax jurisdiction is current. They risk facing high taxes but it can be avoid by setting the company in an inactive status for five years.Purpose: The purpose is to describe the inactive company rules and the verdict from the Swedish Supreme Administrative Court. Also to investigate how this verdict will affect company sellers.Method: Based on a case study and by analyzing the Swedish Law conclusions has been determinate.Result: A dormant company must be inactive for five years, and then the company can benefit from a different taxation. The owner and it´s relatives can´t be active in the company during this five year period.
Ändringen av artikel 7 i OECD:s modellavtal : En komparativ studie
States have sovereignty in deciding how to tax business profits. If two states wish to tax the same profit that belongs to the same taxpayer, double taxation will arise. The increasing number of multinational companies gives rise to double taxation problems and the states have to co-operate to find out how to avoid such problems. The OECD Model Tax Convention includes an article in how to determine the rights to tax business profits. This article has been a subject of discussion and a committee of the OECD has been working to develop a new article 7.The work in proposing this new article has had as its aim to reassure that the interpretations of this regulation is made in the same way.
Svenska fastighetsbolags resultat samt kassaflöde för och efter införandet av IAS 40
The connection between accounting and taxation goes back to the 1920s laws of the named areas. A proposal has now been brought forward, the so-called SamRoB-investigation, which means that the connection between accounting and taxations should be decoupled.The authors? aim with the study is to investigate what a possible decoupling between accounting and taxation, i.e. the formal connection and the untaxed revenues, implicates for the auditor´s work.A research has been done by interviewing two authorized auditors and one authorized consultant of accounting to get a view in how the auditor?s works could be affected.
Vilka konsekvenser har Lex Uggla för fåmansbolag och deras ägare?: -En studie av 50 företag i Stockholm
This thesis analyzes the consequences of ?Lex Uggla? ? a law concerning the boundaries between firm and individual with respect to wealth taxation ? for small businesses, with more than 3 million SEK in over-liquidity. There are two main findings of this thesis. Firstly, the wealth taxation of non-operational assets seems to be an inefficient tax which costs the Swedish welfare system much more than it generates. Secondly, the change in actions among entrepreneurs following the extensive news coverage following the tax authority?s charges against the company of the well-known artist, Magnus Uggla (hence ?Lex Uggla?) illustrates that neither changes of rules nor new applications of rules is necessarily sufficient for an agent to change course of action.
Design of a Direct-conversion Radio Receiver Front-end in CMOS Technology
In this Master's thesis, a direct-conversion receiver front-end has been designed in a 0.18um CMOS technology. Direct-conversion receivers (DCR) have obvious advantages over the heterodyne counterpart. Since the intermediate frequency (IF) is zero, the problem of image is circumvented. As a result, no front-end image reject filter is required and the channel selection requires only a low-pass filter, which makes it easy to integrate directly on chip. However, the DCR also suffers from several drawbacks such as extreme sensitivity to DC offsets, 1/f noise, local oscillator (LO) leakage/radiation, front-end nonlinearity and I/Q mismatch.
Sverige som en del av harmoniseringen : En studie av en tänkbar frikoppling mellan redovisning och beskattning
Sedan lång tid tillbaka har mycket diskussioner och debatter framförts kring det starka sambandet mellan redovisning och beskattning och det råder frågor kring om sambandet skall finnas kvar i Sverige eller inte. Det finns mycket fördelar med en frikoppling, men även nackdelar som kan sätta Sveriges redovisningstradition i en förändring.Syftet med uppsatsen är att framföra de olika förändringar Sveriges redovisningstradition skulle kunna utsättas för i samband med en frikoppling och även lista de olika för- och nackdelar med sambandet utefter revisorer och Skatteverket. För att uppfylla syftet har en empirisk undersökning med tre kunniga respondenter utförts. Meningen är att ta reda på hur frikopplingen skulle kunna förändra arbetssättet hos de utvalda respondenterna.Undersökningen som genomförts har visat att det råder mycket separata åsikter och diskussioner kring förslaget om en frikoppling. Det har visat sig att det skulle uppstå fler nackdelar än fördelar för både revisorer och Skatteverket i början av en frikoppling.
Klassficering av förmögenhetsöverföringar inom bolagssektorn : ur ett civilrättsligt och skatterättsligt perspektiv
There exist a number of different types of value transfers between companies in a group. Most of these transfers are undertaken on the basis of private law. These transfers also give rise to tax law consequences. Taxation is normally based on how the classifications of transfers are made in private law, which means that there exists a relation between private law and tax law. Despite this relation, the classification is not always made in the same way in private law and tax law.
Att placera konsumenter i fack. En studie i kategoriserande direktmarknadsföring.
This thesis examines the extent to which segmentation and categorization in the context of direct marketing is an efficient way for a company to enhance its marketing effectiveness. The thesis is built on social identity and categorization theory, and tested by using statistical analysis. The conclusion is that segmentation and categorization is indeed an effective way of conducting marketing campaigns..
Principen mot rättsmissbruk inom det svenska mervärdesskatteområdet: är det hållbart?
The VAT Directive (2006/112/EC) does not regulate Member States? opportunities to intervene against tax evasion. The European Court of Justice has clarified the situation in case C-255/02 Halifax. This case establish that the universal principle against the abuse of rights applies to VAT, which means that Member States have the opportunity to redefine transactions not involving a breach of law but nevertheless goes past what the legislature envisaged at the introduction of the provision.A debate has risen as to whether the principle against the abuse of rights is equally ap-plicable in Swedish domestic law on VAT. The administrative court of appeal in Go-thenburg, Case No.
Frikopplingens konsekvenser för revisorernas arbete : En studie om det formella sambandets avskaffande mellan redovisning och beskattning gällande obeskattade vinster
The connection between accounting and taxation goes back to the 1920s laws of the named areas. A proposal has now been brought forward, the so-called SamRoB-investigation, which means that the connection between accounting and taxations should be decoupled.The authors? aim with the study is to investigate what a possible decoupling between accounting and taxation, i.e. the formal connection and the untaxed revenues, implicates for the auditor´s work.A research has been done by interviewing two authorized auditors and one authorized consultant of accounting to get a view in how the auditor?s works could be affected.
Ny Protest? : En fallstudie av rörelsen Planka.nu.
The aim of this paper is to analyse the social movement Planka.nu with reference to the theory of new social movements in order to engage in a discussion about the presence of ?old? tradition and ?new? trends. As well as empirical, the purpose is also theoretical and methodological: to examine, and extend, the discussion about new and old social movements. A qualitative method is used. The analytical framework is based on a combination of theories of social movements and new social movements.
Dubbel bosättning : Bostadens betydelse vid flytt från Sverige
The Swedish tax on income for persons who are unlimited liable to tax is based on his domicile and double taxation treaties between Sweden and other countries are based on his residence. In order to determine a person?s tax liability, the dwelling or home is of vital importance to determine where a person has his domicile and residence.For a person who has moved from Sweden, to be unlimited tax liable here, there must be an essential link. This link can be through previous residence in Sweden, the person is not a permanent residence in a foreign country, in possession of housing for year-around-use or in possession of house property.Sweden has concluded double tax agreements with other countries for the reason to prevent double taxation on the same income. When a taxpayer may be regarded as a resident in two states, the situation must be resolved to avoid that double taxation will arise.
Generalklausulens fjärde punkt i Lag (1995:575) mot skatteflykt : I ljuset av Peru-upplägget
The taxation of various kinds of income which Sweden requires taxpayers to pay results in people undertaking sophisticated tax schemes to avoid paying tax . As a result of this Sweden had to develop its tax laws and insert a general clause in the legislation because the legislator wanted a more preventive effect. This preventive effect results in that the clause is applicable to more various types of tax situations. The clause, found in § 2 law (1995:575) against tax treaty override, states four requisites that must be met for a procedure to be considered tax treaty override. The relevant point for this paper is the fourth item which created interpretation problems among courts.