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704 Uppsatser om Parent-Subsidiary Directive - Sida 1 av 47

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.

Betydelsen av ett moderbolags insyn och kontroll över sitt dotterbolag vid prissättning av koncerninterna lån

Transfer pricing including internal loans have increased in recent years, making it easier for companies to minimize their taxable income. After the Swedish court case Diligentia, there have been discussions regarding the influence of a parent company's transparency and control of the subsidiary with regards to the interest rates on internal loans. In court cases that followed Diligentia, the Swedish Tax Agency argued that a parent company always could be assumed to have sufficient transparency and control of the operations in the subsidiary, and therefore reduce the risk on their debt obligations. This thesis seeks to analyze the effects of the transparency and control a parent company has with regards to interest rates on internal loans. The analysis is conducted by analyzing court cases similar to Diligentia.

En ny bild av ett nytt bibliotek? : Förändringar och marknadsföring på bibliotek, en utvärdering av Skogsbibliotekets "library brand" utifrån studentperspektiv.

The Swedish group contribution rules do not include a right to deduction for cross-border group contributions unless the receiving company is taxable in Sweden. There has been much discussion regarding whether the rules are compatible with EC law. On 11 March 2009 the Swedish Supreme Administrative Court ruled ten cases concerning the right to deduction for cross-border group contributions. In three of these judgments deduction for a group contribution from a Swedish parent company to a foreign subsidiary within the EEA was allowed, despite that the subsidiary was not taxable in Sweden. The main purpose of this master thesis is to analyse whether the interpretation of the Supreme Administrative Court concerning the right to deduction for cross-border group contributions is compatible with EC law.

Rätten till gränsöverskridande förlustutjämning ur ett svenskt perspektiv ? En realitet eller ett spel för galleriet? : En juridisk analys med fokus på Regeringsrättens tolkning av de svenska koncernbidragsreglernas förenlighet med EG-rätten

The Swedish group contribution rules do not include a right to deduction for cross-border group contributions unless the receiving company is taxable in Sweden. There has been much discussion regarding whether the rules are compatible with EC law. On 11 March 2009 the Swedish Supreme Administrative Court ruled ten cases concerning the right to deduction for cross-border group contributions. In three of these judgments deduction for a group contribution from a Swedish parent company to a foreign subsidiary within the EEA was allowed, despite that the subsidiary was not taxable in Sweden. The main purpose of this master thesis is to analyse whether the interpretation of the Supreme Administrative Court concerning the right to deduction for cross-border group contributions is compatible with EC law.

Klassificering av utländska dotterföretag

Background: Companies often invest in foreign subsidiaries and that gives rise to translation exposure. Translation exposure arises with the consolidation of the foreign subsidiary and depends on the rate of exchange that are used for translation of the foreign subsidiary. In time several different methods of translation and recommendations has been developed. Companies listed on OM Stockholmsbörsen shall follow RR8. According to RR8 a classification of foreign subsidiaries as indipendent or integral to the parent company determines which method of translation that should be used.

Franska dotterbolags etableringar på den svenska marknaden.

Today?s globalisation has opened up borders between countries as can especially be seen with the opening of the European Union. This has increased possibilities of communication and transportation, which has provided companies with greater expansion opportunities throughout the world. However, difficulties may occur when companies choose to establish abroad, for instance when French companies establish in Sweden through subsidiaries, the lack of knowledge and understanding, when it comes to the business culture, customs, and values within the host country, as well as the culture and the structure within the company, may contribute to misunderstandings and inability to work in an amalgamated manner. These barriers are a cause of unsuccessful penetration within foreign markets.

Sverige och implementering av EU-direktiv : En fallstudie av badvattendirektivet och arbetstidsdirektivet

The aim of this paper is to explain and compare non-compliance of two EU-directives, ?the quality of bathing water? and ?the working time directive?. This study answers the questions: Why didn?t Sweden implement the directive on bathing water quality and the working time directive correctly? Are the reasons for non-compliance the same or different in the two cases? The paper is designed as a case study and with an explanatory attempt we explain why the two directives weren?t implemented correctly in Sweden. The theoretical approach is based on both general- and EU-specific implementation theories.

Ansvarsskyldighet för aktieägare : Personligt ansvar och skadestånd

Shareholder, who decides to continue with the company, can cause that they become per-sonally liable for its upcoming obligations. Creditors must lodge an appeal against the shareholder to get compensation for the harm they have suffered. The damage rules in Swedish company law are designed to utilize the company?s interest, that is, shareholders and other corporate members shall promote the interests of the company and not cause damage.The rules about compensation that shareholder obligates itself to are difficult to apply and are adapt to the specific cases. For a shareholder to be personally responsible in a real situation a company has to establish a subsidiary company, which is being driven undercapitalized, intended to benefit the shareholder.

Arbetstidsdirektivet och arbetstidslagen - En utredande studie

Sweden is a member of the European Union since 1995. The European Union issues directives that cover different areas. Member states must implement these directives into their national legislation. The European council issued in 1993 a directive that took action on the organization of working time, also known as the working time directive. The full name is: Council directive 93/104/EC of 23 November 1993 concerning certain aspects of the organization of working time.

 Moderbolagsperspektiv kontra enhetsperspektiv  : - motiv och konsekvens i teori och praktik

Abstract The development towards an international accounting standard implies that Swedish groups of companies that are not quoted on the stock exchange can use a parent company perspective or an entity perspective while making their group accounting. The purpose of this study is to describe and explain the motives behind the groups of companies choice of perspective and to show how these motives agrees with the effect it has on the profit and loss account and on the balance sheet.The study includes four fictitious groups of companies based on real groups of companies. Every group of companies includes 1-3 subsidiary companies, where at least one is owned by the parent company with 51-70 %. Some assumptions were made before the consolidation.Relevant key numbers have been calculated according to both perspectives and then compared. A total of three semi structured interviews have been carried out two with representatives for the real groups of companies and one with a chartered accountant.

CSR i leverantörskedjan : Företags möjlighet att reglera, kontrollera och genomdriva

The first aim of this study is to examine what the differences are between the Classic directive (directive 2004/18/EC of the European Parliament and of the Council of 31 March 2004 on the coordination of procedures for the award of public works contracts, public supply contracts and public service contracts) and the Revised Classic directive (directive 2014/24/EU of the European Parliament and of the council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC) when it comes to social considerations in public procurement. The second aim is to examine if the revision of the directive has solved the prior existing problems regarding social considerations in public procurement. In this paper a traditional European legal method is used. The examinations show a number of things, including the Revised Classic directive involving codification of case law, references to other sources of law and some clarified rules as well as new provisions. The regulations regarding reserved contracts, technical specifications, and selection criterion are satisfied in the Revised Classic directive.

Förslag till obligatorisk skatteflyktsklausul i moder-/dotterbolagsdirektivet

The first aim of this study is to examine what the differences are between the Classic directive (directive 2004/18/EC of the European Parliament and of the Council of 31 March 2004 on the coordination of procedures for the award of public works contracts, public supply contracts and public service contracts) and the Revised Classic directive (directive 2014/24/EU of the European Parliament and of the council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC) when it comes to social considerations in public procurement. The second aim is to examine if the revision of the directive has solved the prior existing problems regarding social considerations in public procurement. In this paper a traditional European legal method is used. The examinations show a number of things, including the Revised Classic directive involving codification of case law, references to other sources of law and some clarified rules as well as new provisions. The regulations regarding reserved contracts, technical specifications, and selection criterion are satisfied in the Revised Classic directive.

Sambors rätt att ärva varandra : ? den svenska lagstiftningens brister i ett nordiskt perspektiv

The first aim of this study is to examine what the differences are between the Classic directive (directive 2004/18/EC of the European Parliament and of the Council of 31 March 2004 on the coordination of procedures for the award of public works contracts, public supply contracts and public service contracts) and the Revised Classic directive (directive 2014/24/EU of the European Parliament and of the council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC) when it comes to social considerations in public procurement. The second aim is to examine if the revision of the directive has solved the prior existing problems regarding social considerations in public procurement. In this paper a traditional European legal method is used. The examinations show a number of things, including the Revised Classic directive involving codification of case law, references to other sources of law and some clarified rules as well as new provisions. The regulations regarding reserved contracts, technical specifications, and selection criterion are satisfied in the Revised Classic directive.

Tvistlösning online vid konsumenttvister

The first aim of this study is to examine what the differences are between the Classic directive (directive 2004/18/EC of the European Parliament and of the Council of 31 March 2004 on the coordination of procedures for the award of public works contracts, public supply contracts and public service contracts) and the Revised Classic directive (directive 2014/24/EU of the European Parliament and of the council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC) when it comes to social considerations in public procurement. The second aim is to examine if the revision of the directive has solved the prior existing problems regarding social considerations in public procurement. In this paper a traditional European legal method is used. The examinations show a number of things, including the Revised Classic directive involving codification of case law, references to other sources of law and some clarified rules as well as new provisions. The regulations regarding reserved contracts, technical specifications, and selection criterion are satisfied in the Revised Classic directive.

Människosmuggling : Hemliga tvångsmedel för att bekämpa den organiserade brottsligheten

The first aim of this study is to examine what the differences are between the Classic directive (directive 2004/18/EC of the European Parliament and of the Council of 31 March 2004 on the coordination of procedures for the award of public works contracts, public supply contracts and public service contracts) and the Revised Classic directive (directive 2014/24/EU of the European Parliament and of the council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC) when it comes to social considerations in public procurement. The second aim is to examine if the revision of the directive has solved the prior existing problems regarding social considerations in public procurement. In this paper a traditional European legal method is used. The examinations show a number of things, including the Revised Classic directive involving codification of case law, references to other sources of law and some clarified rules as well as new provisions. The regulations regarding reserved contracts, technical specifications, and selection criterion are satisfied in the Revised Classic directive.

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