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2862 Uppsatser om Home State Taxation - Sida 1 av 191

Internprissättningsproblematiken i ljuset av förslaget om hemlandsbeskattning för europeiska koncerner

Throughout this thesis three main factors have been identified that can be out of significance for transfer pricing in multinational companies if the proposal for Home State Taxation is adopted. These factors are rules for calculation of the tax base, rules for dividing costs over periods and the tax rate. The formula for sharing profits will also become a factor that can have an impact on the European companies'incentives for transfer pricing interacting with above-mentioned factors. The effects of transfer pricing aiming at reducing the total amount of the taxation burden for a group of companies will be strongly reduced in the future if the proposal is adopted. Incentives for transfer pricing will loose importance, though not disappear altogether.

Is Home State Taxation a step forward for SMEs? An SME?s ability for growth and integration in the EU after the HST tax reform

Small and Medium sized Enterprises (SMEs) within the European Union are currently facing many challenges one being access to financing due to high risk and probability of default, another being cross-border taxation issues with double taxation and information asymmetry. Since the aim within the EU is to be the most competitive and dynamic knowledge-based economy in the world with sustainable economic growth and social cohesion it is essential that the EU operates as a single market. Despite this need, harmonization continues to be far from achieved in the area of direct taxation which also affects the integration and growth opportunities for SMEs. In the Agenda for Entrepreneurship, the Home State Taxation regime, which is based on formula apportionment, has been proposed by the Commission as one option in order to mutually recognize the different Member States? taxation systems to facilitate cross-border activities and reduce ?red-tape?.

Beskattning av pokervinster

The purpose of the paper is to examine the state of law concerning taxation of Swedish poker winnings. The main findings are: Poker is seen as a random and adventurous game. Poker is thereby considered a lottery. Swedish poker winnings are thereby not taxed as income. Foreign poker winnings are taxed as income.

Beskattning av skadestånd och liknande ersättningar

The purpose of the thesis is to illustrate how payments of damages between companies are treated from a taxation point of view, and to analyse, in a tax law perspective, the consequences that follow the transactions. Furthermore, a comparison is made between damages and transactions similar to damages, such as amicable settlements and fines between companies, to ascertain whether they are treated similar. Finally, there is an analysis of the consequences of taxation of insurances, both premiums and compensations, followed by a comparison with the consequences of taxation of damages..

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.

Vad staten bör göra. En deontologisk och en preferensutilitaristisk analys av beskattning och statliga verksamheter.

This essay is a normative analysis concerning the question of whether the government should be allowed to use taxes to finance the state. What kind of ethical problems arise when the government use taxation? If it is possible to justify taxation, despite potential moral issues, then what should the government do with the funds they have collected? What kinds of government functions are morally justified? Is it merely the kinds of functions that are supposed to uphold negative human rights; or should the government provide health care, education and even culture for the citizens? This analysis aims to answer those questions and also formulate a principle about what the government should be occupied with, if anything at all. In order to achieve this I mainly use the terms freedom and justice to analyse ethical problems. The ideas of John Rawls and Robert Nozick are essential in this project.My answer is that taxation is justified as long as the purpose is to maintain the most fundamental human rights and also under other special circumstances such as if an individual cannot find a way to finance basic education or necessary health care.

Autonomi och gemensamma strävanden

The liberal state, it has been argued, must be neutral between different conceptions of the good. Embodying ideals such as fairness and impartiality, state neutrality is intuitively appealing, but working as a restraint for state actions it is somewhat unsatisfactory. People make mistakes about their lives and people live less valuable lives than they could do. To then restrain the state from doing as much good as it can seems just as unappealing as neutrality at first seemed appealing. In this paper, a possible solution to this dilemma is presented.

Uttagsbeskattning och beskattningsinträde : En analys av förenligheten med etableringsfriheten

AbstractEver since Sweden joined EU Swedish law has to be compatible with EU law. Swedish law cannot state anything that may restrict the freedom of establishment. This means that companies are free to change their resident within the EU without any restrictions. National rules regarding exit tax states that companies who wants to move their business out of Sweden is taxed as if their assets has been disposed of at the exit time. These rules have been found to restrict EU law according to case RÅ 2008 ref 30.

Uttagsbeskattning vid gränsöverskridande fusioner : Är den svenska regleringen i 22 kap. 5 § 2 p. IL. förenlig med etableringsfriheten?

Freedom of establishment statutes that restriction of citizens within the EU can not occur. A citizen should be free to establish themselves in a Member State and not be hindered if they choose to leave the State. "Citizens" also includes legal persons such as companies. Legislations in Member States which prevents the freedom of establishment shall be prohibited. When a company chooses to merge across borders and thus cease to be a Swedish company, the Swedish rules for exit taxation applies.

3:12-reglerna : Tillämpning av löneunderlagsregeln

The 3:12-provisions are part of a legal system specified for owners of close corporations (companies owned and managed by a small group of businesspeople), for taxation of capi-tal gains and dividend. The reason for special rules for the taxation of these owners is to prevent them from transforming their income, to only be subject of the lower taxation of capital gains, instead of income of service. Since the rules were put in force, they have been subject to several changes. The most recent changes took effect on the 1 January 2006. They involve a higher importance for the rule of salary-based taxation.

Sambandet mellan redovisning och beskattning : Koppling eller frikoppling

Since January 1st 2005, public companies within the European Union shall prepare their consolidated accounts in conformity with the international accounting standards. The adopted accounting standards are IASB?s IAS/IFRS completed with interpretations. Furthermore, member states may permit or require public companies to prepare their annual accounts according to IAS/IFRS. Sweden has not yet given companies the ability to use IAS/IFRS in the annual accounts due to taxation difficulties the strong relationship between accounting and taxation brings.

En studie av Föreningen Värmlands Arbetarkvinnors Semesterhem för husmödrar; exemplet Frykenstrands semesterhem 1943-1974 : Hur omsattes statens visioner i praktiken?

Sweden had in the early 1930's the lowest birth rate in the world. Population Commission which was established in 1935 concluded that one of the biggest social problems was the working women?s heavy workload. To deal with the low birth rate reforms and programs were founded both in order to help the women but also in order to support the inadequate motherhood. Government grants were set up to start the so-called vacation home for housewives where the government?s visions of the vacation homes were active rest and recreation.     Based on the Leisure Inquiry report regarding vacation homes for housewives - the purpose of this paper is to examine how the government visions regarding vacation homes for housewives were practiced and how the future of prevailing gender contract affected the holiday home.

Lissabon Fördraget : Värnet mot Globaliseringen?

 Dissertation in political science, C-level by Niklas Andersson, Spring Semester 2009. Tutor: Arne Larsson?The Treaty of Lisbon ? The Defence against Globalization??In the modern world globalization have undermined the nation-state and left it without the right measurements to adequately deal with the social and economic unrest that follows in its way. The states, built on contract theories, have an obligation to protect its citizens from the state of nature which seems to have failed as globalization has changed the rules.The purpose of this dissertation is to examine the contract theories of Thomas Hobbes, John Locke, Jean-Jacques Rousseau and John Rawls to identify the elements of a state and create a modern and ideal contract theory. The treaty shall then be used on the Treaty of Lisbon as it can be seen as a contract between the European states to create an entity in the shape of the European Union with the power to defend Europe from the unrest created by globalization.My question for this was as follows:Is the new treaty for the European Union acceptable as a new social contract according to the social contract theories?During my research the following criteria?s for a social contract was found:1.

Att komma hem : Coming home

In this essay I analyze the meaning of the concepts home and at home and the feeling of coming home. What is a home and what different interpretations are there regarding the concepts of home and being at home? What kinds of feelings are aroused by coming home? The world we live in offers great opportunities to travel, which in itself creates a perspective on the meanings of the concepts. The world we live in also forces people to move from their homes, families and countries due to various reasons, which creates various problems and a certain urgency concerning the concepts. I describe basic terms concerning the concepts, both regarding concrete definitions and more abstract notions, and then compare them with my own reflections.         Based on my writing project Coming home I discuss these questions in various ways.

Den svenska kupongbeskattningen av utländska fondbolag och dess förenlighet med EU-rätten : Bör det svenska regelverket förändras

AbstractThe purpose of this thesis has been to investigate if the Swedish legislation concerning taxation of dividends to foreign investment funds is in violation to EU law. Furthermore, the thesis will analyze if the Fondskatteutredningens suggestions to changes in the current legislation is appropriate to the purpose it tries to obtain.Today there is a difference in the taxation of dividends paid to Swedish investment funds and foreign investment funds. Dividends paid to foreign investment funds is being taxed in accordance with the Coupon Tax Act (1970:624), in which no deduction of the tax is possible. Swedish investment funds on the other hand have the possibility to deduct as much of the received dividends that they have given in dividends to its shareholders.The difference in the taxation between investment funds because of origin has been reviewed by both Swedish court and by the European Court of Justice. It has in these cases been up to the courts to review if a difference in taxation of dividends could constitute a violation of the free movement.

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