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..

Future climate changes may lead to an interest of alternative and foreign forest tree species in order to spread the risks in forestry. Douglas fir, Sitka spruce, Freemont cottonwood and hybrid aspen are examples of popular foreign tree species that along with western red cedar could have a future in the Swedish forests.Södra Skogsägarna and SLU have collaboration in establishment of foreign species in Swedish forests.The purpose of this study was to analyze and present the establishment of western red cedar, and to survey and illustrate injuries of freeze drying and other damages like deer browsing, vegetation and insect attacks. The study included four different provenances, and spruce as a reference, planted in two locations ? Asa and Släne.Western red cedar is despite its name a conifer of the cupressaceae family with defined secondary characteristic and gets along well with an overstory. Western red cedar grows often in mixed stands with similar conifers and its natural habitat is within and in the area near to British Columbia.The study included two series of field inventories, one made in the summer and one in the autumn 2013, three growing seasons after plantation.

This thesis aims to describe and characterise the foreign policy change the United States has experienced towards Europe. This thesis claims that the United States is presenting a more supportive attitude today towards the development of the European Union. This more positive attitude has developed during successive U.S. administrations and has become visible since the end of the Cold War.Washington is today less ambiguous and less ambivalent towards the integration of Europe. The United States appreciate that a common foreign- and security policy in Europe is in accordance with American interests.

Title: Det nya Ryssland - En inblick over Rysslands utrikespolitik under 2000-taletAuthor: Tim Balder and Jens KindhLinnaeus UniversityDepartment of Political ScienceAutumn term 2011The purpose of this thesis is to gain a better understanding of how the Russian foreign policy is, how it is conducted and how it may develop in the future. To do that, we are going to try to answer the following questions:What characterizes Russia's official foreign policy?What theories are there for the Russian foreign policy?How can the various theories explain the Russian foreign policy actions at the international level?Our theory is to try explaining how the Russian foreign policy is continuing its development during the 21st century through three theories known as the Western liberalism, Pragmatic nationalism and Fundamental nationalism. Furthermore, to explain Russia's foreign policy and their behaviour, we are going to use the two foreign policy doctrines from 2000 and 2008. In addition, books and articles will also be used to explain how Russia's foreign policy is conducted and developed..

This Master Thesis investigates changes in Thailand's foreign policy towards its neighbouring country Burma. It argues that Thai foreign policy towards Burma has experienced major changes during four periods between 1945 and the present. The thesis investigates these foreign policy changes during the four periods. What changes occurred? What were the reasons for the changes? What reasons dominated during what periods? The four periods of Thai foreign policy changes towards Burma and the common history of the two countries since their respective foundations does not suggest a stable peaceful relationship or a bitter hostile relationship leading to war.

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.

Title: Det nya Ryssland - En inblick over Rysslands utrikespolitik under 2000-taletAuthor: Tim Balder and Jens KindhLinnaeus UniversityDepartment of Political ScienceAutumn term 2011The purpose of this thesis is to gain a better understanding of how the Russian foreign policy is, how it is conducted and how it may develop in the future. To do that, we are going to try to answer the following questions:What characterizes Russia's official foreign policy?What theories are there for the Russian foreign policy?How can the various theories explain the Russian foreign policy actions at the international level?Our theory is to try explaining how the Russian foreign policy is continuing its development during the 21st century through three theories known as the Western liberalism, Pragmatic nationalism and Fundamental nationalism. Furthermore, to explain Russia's foreign policy and their behaviour, we are going to use the two foreign policy doctrines from 2000 and 2008. In addition, books and articles will also be used to explain how Russia's foreign policy is conducted and developed..

It is more common now to purchase products and services on the Internet. More and more companies choose to sell their services and products this way. Some services and products the customers can get delivered directly to their computers. Therefore, it is important for entrepreneurs to know when they risk a permanent establishment in another country due to their Internet based activity. If the company gets a permanent establishment in the other country, the other country can tax the income which is relatable to the company?s permanent establishment.

This master of economics paper discuss that the globalization has lead to increasing internationalization among small Swedish IT- companies in the service sector. Sweden has a long history of foreign trade but in the beginning of the industrialization only large companies that produced goods answered for the foreign trade. Before, the Swedish companies begun their operations abroad in fairly nearby markets and only gradually penetrated far-flung countries. Now this is no longer possible. When small companies nowadays seek growth in other countries there is no time internationalize with the same approaches as before, especially when the company offers a service.

 Introduction and research question: In the global media field, global expansion has become more common and is a way for media companies to reach out to a broader audience. Both advantages and disadvantages come with a global expansion and there are several cultural differences that have to be considered. This thesis will deal with the cultural differences and discuss how a Swedish media company efficiently goes about establishing in Vietnam. This leads us to this thesis' research question: How does a Swedish media company succeed in Vietnam? Purpose: This thesis' purpose is to find out what media companies do to successfully acclimate to the Vietnamese culture and the important aspects of the cultural differences to consider.Delimitation: In order to present a thesis with greater depth and acquire a deeper understanding, the study is limited to examine Swedish media companies and what intercultural aspects are important to consider when establishing in Vietnam. Method: The research we have done is based on interviews, which we thought could give us the accurate information and a good base to stand on.

The purpose of this essay is to examine the importance of personal election for candidates of foreign background. I made this, first, by map and comparing the candidates of foreign background in the recent Swedish and Finnish parliamentary election. Second, I analyze what conceptions candidates of foreign background, who was nominated in the 2006 municipal election in Örebro, have about the personal election. The result from the first study shows that personal election had a negative impact on candidates of foreign background in both the Swedish and Finnish parliamentary elections. The result from the second study shows that candidates of foreign background have both positive and negative conceptions about the personal election.

Abstract The purpose of this study is to examine if the Swedish policy of foreign affairs has been changed due to the Swedish enter as members in the European Union. The research method used for this essay has been a comparative case study between the Swedish and Norwegian declared policy of foreign affairs and it strives to answer the research question, which is if the Swedish declared policy of foreign affairs has been changed in character due to the Europeanization. The theoretical framework of this study consists of Europeanization as a comprehensive theoretical perspective. I order to answer the research question a classification schedule has been elaborated to examine the objectives of the Swedish and Norwegian declared policy of foreign affairs. The analytical method of this part has been a quantitative and qualitative approach.

Objective: The objective of this thesis is to investigate how Scania has attained success to establish on the Indian market and to inquire into the establishment process of Scania and their entrance in the Indian market. The thesis describes different factors such as the product, mode of entry, time of entry and choice of market that play a role when a company establishes and invest in a foreign market.Method: This thesis is limited to the process of establishing Scania on the Indian truck market. A qualitative approach has being utilized in this study, consisting of interviews withStaffan Sjöström, development manager at the R&D department, Koen Knoops, vice president at Financial Services and Henrik Fagrenius, former managing director for Scania in India. Data collection from various journals and articles have been conducted for the presentation of the number of sold newly registered trucks in comparison to the number of sold newly registered trucks in India by Volvo, Tata Motors and Ashok Leyland during 2010, 2011, 2012 and the first three quarters of 2013.Theory: With a starting-point in empirism, we have used a theoretical frame of reference to describe Scania´s establishment process. Scania makes use of an internationalization strategy, namely Market Selection, Time of Entry and Entry mode and the network model, which describes the process of establishing on a foreign market as a business association with various players on the market.

The production of oilseed rape is an important issue in Sweden and those who never have grown oilseed rape (OSR) are now willing to try. It is always a risk to grow oilseed rape, specially winter OSR, because of outwintering. This risk increases as you go north and therefore establishment and autumn growth is very important. These are some of the reasons that I have chosen to write about the establishment of winter oilseed rape in Middle Sweden. There are many factors that influence the outcome of the establishment, e. g.

We have inquired into how the amount of foreign news has changed over the last 30 years in two major Swedish newspapers, which subjects and regions has dominated the content of the foreign news and what subjects dominate the reporting from certain regions. This was done with a quantitative analysis of subjects and regions written about in 1100 news texts during a week in each year of 1978, 1988, 1998 and 2008. To further broaden our study, we also charted with the analysis how the newspapers domesticate foreign news and how they use international news agencies. As a basis for our discussion we use Van Ginnekens theories of world news centres, Westerståhl & Johanssons and Galtung & Ruges theories of foreign news selection as well as the theories of Hjarvard and Biltereyst about the domestication of foreign news due to commercial pressures and objectives on the newspapers. Our result of the amount of foreign news in the two newspapers is also compared to several similar empirical studies by different researchers.