Sökresultat:
1614 Uppsatser om International taxation - Sida 2 av 108
Mervärdesbeskattning av elektroniska tjänster : Är beskattningen förenlig med neutralitetsprincipen?
AbstractValue Added Tax, VAT, is a general consumption tax that is added to almost all consumption of goods and services. Despite the extensive work of harmonization of the VAT system relating to electronic services, it can be difficulties in determining the taxable land, something that could affect the internal market in a negative way. The Swedish companyStardollABwas double taxed on certain electronic services that they provided consumers in theUK. The problems that lead to double taxation must be identified to ensure free competition and free movement within the internal market. The principle of neutrality pervades the whole of the EU VAT system which can be derived from principles of the Treaty, establishing the common market, and the introduction of the VAT Directive.
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.
International negotiation: pre-negotiation in Swedish
companies
International negotiation is the link between international planning and implementation. The ability to negotiate successfully may very well depend on the efforts being put into preparatory activities, leading to the purpose of this research, to gain a better understanding of pre-negotiation in an international context, by exploring, describing and partly explaining the process. Personal interviews were conducted with two Swedish international companies to obtain thorough information within the area. The collected data from these two cases are discussed, compared and then finally used to draw general conclusions. The study indicates the different issues that either occur or should be considered prior to the first formal meeting in an international negotiation.
Bristande reciprocitet i anledning av forskningsbidrag
Every year approx. 110 billion SEK is being used In Sweden to finance research. The government contributes with 22 percent, i.e. approx. 25 billion SEK.
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.
Koncernbidrag med avdragsrätt efter omstruktureringar inom koncerner
By means of group contributions the legislator has made it easier for company groups to transfer profits from a parent company to a subsidiary. A parent company can choose to reconstruct by acquire a company, create a subsidiary or perform a partial fission. The choice can affect the possibility for a parent company to perform a group contribution with deduction right.The parent company has to own more than 90 percent of the subsidiary?s shares for a whole taxation year or since the subsidiary began to carry out any economic activity in order to perform group contributions with deduction right. If a subsidiary is acquired, it has to be owned for a whole taxation year before group contributions with deduction right can be made, unless the acquired company never has carried out any economic activity before.
"Annan finansiell verksamhet" - En tolkning i ljuset av CFC-lagstiftningen : En tolkning i ljuset av CFC-lagstiftningen
The initial provisions concerning CFC-legislation were introduced 1990 and has since been subject to several revisions and adaptations. The fundamental purpose of the CFC-legislation is to prohibit and prevent tax evasion undertaken by such companies that own other foreign companies where generated income is subject to low rates of taxation. The CFC-legislation aims to provide the Swedish government with an op-portunity to tax this income. This is important in order to prevent tax avoidance and preserve the integrity of the system of taxation within Sweden. In order for the CFC-legislation to be as effective as possible there must exist a clear way of defining which activity that is to be regulated within its scope.
Speglingar, reflektionens redskap för den kvalificerade samtalspartnern
The initial provisions concerning CFC-legislation were introduced 1990 and has since been subject to several revisions and adaptations. The fundamental purpose of the CFC-legislation is to prohibit and prevent tax evasion undertaken by such companies that own other foreign companies where generated income is subject to low rates of taxation. The CFC-legislation aims to provide the Swedish government with an op-portunity to tax this income. This is important in order to prevent tax avoidance and preserve the integrity of the system of taxation within Sweden. In order for the CFC-legislation to be as effective as possible there must exist a clear way of defining which activity that is to be regulated within its scope.
Sveriges CFC-reglering : En anpassning till EG-rätten
The Swedish CFC rules imply a taxation of Swedish partners of foreign legal persons subject to low income tax, which is based on a fictitious distribution. Thus, tax is levied even if the dividend has not been paid to the shareholder. The aim of the Swedish CFC legislation, which was put into force in 1990, was to prevent tax evasion and to protect the Swedish tax base. The reason was that the foreign exchange control was abolished, which made investments in foreign countries possible for Swedish companies. A CFC legislation was considered necessary for Sweden in order not to lose tax revenues.The legislation was strengthened on January 1st 2004 as a consequence of the abolished taxation of capital income of commercial shares.
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.
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?.
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.
?What is going on??: En studie av internationella studenters informationsbehov på Högskolan i Borås
The purpose of this Bachelor?s thesis was to examine the information needs of the international students at the University of Borås. A further aim was to examine the types of information sources the international students was using to satisfy their information needs and the environmental factors keeping them from achieving this. This was done through focus group interviews with international students from four different countries ranging from the ages 20 ? 35.