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2671 Uppsatser om Taxation of interest - Sida 3 av 179

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.

Investeraravdraget : En ändamålsenlig lösning på den skattemässigt asymmetriska behandlingen av bolag finansierade genom eget kapital respektive lånat kapital?

Companies financed through borrowed capital are allowed a tax deduction for the costs re-lated to their borrowed capital. A similar tax relief for companies financed through share-holder?s equity does not exist, why these companies are taxed higher than companies fi-nanced by borrowed capital. The result is that there is an asymmetric tax treatment of companies depending on how they are financed.The autumn of 2012, the Swedish government presents a proposal for an investor deduc-tion which seeks to equalize the above mentioned asymmetry. The proposed investor de-duction is a tax relief for investments in shares in a startup- or small company equal to 50 percent of the acquisition cost of that investment.The venture capital deduction, which in this thesis is treated as an alternative to the inves-tor deduction, is an interest-free tax credit which significate that two-thirds of the acquisi-tion cost is deductible from taxation at the time of the acquisition.

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.

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.

Matematikintresse. Lärares uppfattningar av ett attitydmål

AimThe main aim of this study was to find out how teachers reflect on their work with developing pupils? interest towards mathematics in grade nine. As a teacher in mathematics, it is important to be aware of different views on interest towards mathematics and how it is possible to work in that direction. Since developing interest towards mathematics is written the in syllabus as criteria for teaching mathematics in grade nine, it is important to know and take an active role in finding ways to approach the issue.Main issues? How do teachers in grade nine reflect over their work with development of interest towards mathematics?? How are teachers? Beliefs Systems reflected in their work with interest?MethodThe main focus of this study was teachers? perspective on their own work on developing interest towards mathematics.

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.

Avskaffande av beskattning av kapitalvinster på företagsägda näringsandelar : En studie av effekterna på fåmansföretagsreglerna i IL 57 kap.

1998 års företagsskatteutredning föreslår i SOU 2001:11 att beskattningen av kapitalvinster på företagsägda näringsandelar (BKN) avskaffas. Denna uppsats behandlar frågan om hur ett sådant avskaffande skulle påverka de s.k. fåmansföretagsreglerna i IL 57 kap. I uppsatsen visar jag att de nuvarande reglerna i IL 57 kap. inte skulle förmå uppfylla deras syfte vid ett eventuellt avskaffande av BKN.

Brott & Skatt : En undersökning av nystartade aktiebolag på Skattekontor Östra Göteborg

BACKGROUND The economic crimes related to the taxation authorities (SKM), aim at evading paying taxes and/or wrongly obtaining tax revenue. SKM has noticed that many newly established companies have intended to be carried on, only for a short period of time and with the aim of generating grant-revenues and in the meantime omit to pay or wrongly account for taxes. SKM wants to investigate the possibilities to develop a method of analysis to identify those corporations. PURPOSE The purpose of this essay is to make a survey of, and identify companies, who fail in their obligations concerning income-tax return and paying taxes and charges and to try to see what is characteristic for those companies in order to find out a method of analysis. Further a study of literature will be done especially concerning who will commit economic crimes and the reasons why they do it.

Generationsskifte : Särskilt om gåva och blandade fång

All small- and medium-sized family owned enterprises need to sooner or later undergo a change of ownership. When the elder generation is approaching their retirement they have to make a choice; either hand over the business to the younger generation or sell it to an outsider. The succession of the family owned business can create a life long dilemma for the entrepreneur. From the view of taxation there are, according to current legislation, no reasons to plan the succession to the younger generation. If no preparation has been done, the optional law system concerning inheritance will divide the property left.

Fast driftställe enligt OECD:s modellavtal i ljuset av elektronisk handel

The purpose of this thesis is to examine whether the concept of permanent establishment, as defined in Article 5 of the OECD Model Tax Convention on Income and Capital, is applicable to electronic commerce and if so whether the current definition is able to appropriately deal with the challenges of electronic commerce.In 2003, the OECD added a new section to the Commentary on the Model Tax Convention on Article 5. The new section is a clarification on the application of the permanent establishment definition in electronic commerce.The current definition of permanent establishment in the Model Tax Convention relies on the physical presence of a foreign corporation as the threshold for source taxation. While the current definition, prima facie, might be applicable on electronic commerce, the highly mobile nature of electronic commerce might affect the current revenue distribution equilibrium between states..

Källskatt i ett EU-perspektiv : Diskriminering inom nationell rätt?

According to Swedish tax legislation, investment funds are taxed differently depending on if the are Swedish or foreign. The difference between the investment funds lies within the taxation of received dividends and the opportunity to shift the liability of tax of received dividends on to the funds shareholders. This measure is only available to Swedish funds. The question in this thesis is whether this difference is discriminatory against foreign investors and therefore constitutes a forbidden restriction against the free movement of capital stated in article 63 EUF Treaty.The European Court of Justice (ECJ) has given several preliminary rulings on this type of legislation and its compatibility with the principle of free movement of capital. It is not compatible with the free movement according to the court.

Anställdas förvärv av värdepapper : Beskattningstidpunkten när förvärvet är förenat med förfoganderättsinskränkningar

It has become increasingly simple for companies to offer its employees shares in the form of incentive or option plans to acquire.  Companies motivate incentive plans with employee buy-outs that it will lead to higher involvement of work. The offers are often associated with disposal restrictions to the employee such as not immediately dispose of shares or that the employees will have to remain of employment within a certain timeframe. The problems with disposal restrictions are that it makes it difficult to determine the point of taxation.When shares deemed acquired at the time of share subscription the benefit will be taxable as income from service and the increase in value income from capital. When shares are deemed to be acquired only after cessation of disposal restrictions this will result in that the benefit is taxed only once.After the Supreme Administrative Court rulings in 3167-09 and 3168-09, it is now obvious that the acquisition is deemed to occur at the time of acquisition. The problem is not yet solved because the constant development of the security market needs to be considered.

Koncernbidragets hantering ur ett ABL-perspektiv: - En analys av det vedertagna tillvägagångssättet

The use of group contribution between consolidated firms is a common phenomenon in Sweden where taxation is not based on the return on the consolidated level but on the return on the individual firms. However, the process of handling the group contribution does not work without problems. This thesis analyzes three main issues where group contributions oppose the Swedish Companies Act. ? The Swedish Companies Act enacts the decision regarding group contributions to be made at a shareholder?s meeting.

Den svenska swapspreadens förklaringsfaktorer : en empirisk analys

This paper presents empirical evidence on the determinants of interest rate swap spreads in Sweden during the period 1999-2003. The results suggest that the spread between STIBOR and the general collateral repo rate is positively related to shorter maturity swap spreads. The risk premium associated with commercial bonds is positively related to swap spreads of all maturities. A negative relationship is observed between the term structure of interest rates and swap spreads. The short-term interest rate is positively related to spreads with shorter maturities.

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