BEPS-projektet startades år 2012 för att förhindra att skattesubjekt använder kryphål i skatteavtalen och staternas nationella lagstiftningar för att erhålla skatteförmåner. År 2013 utgav OECD en handlingsplan som identifierar 15 åtgärder som ämnas vidtas. Åtgärdspunkt 6 reglerar problematiken kring hur skatteavtal missbrukas genom att skattesubjekt ?shoppar? efter jurisdiktionen med det skatteavtal som leder till den förmånligaste beskattningen. Åtgärdspunkt 6 föreslår att en specifik LOB-regel eller en generalklausul, PPT-regeln, införs i OECDs modellavtal för att motverka det aktuella förfarandet.

Under Swedish tax law; the general clause in the Tax Avoidance Act is a method to prevent tax evasion. The purpose of the general clause is to prevent any tax avoidance procedures that the legislator has not been able to foresee. For the general clause to be applicable, four prerequisites need to be met. This thesis analyses the fourth prerequisite based on the principle of legality. The prerequisite concludes that a determination of the tax base, based on the procedure in question, is in conflict with the purpose of the legislation.

In his master thesis, Johan Jutterström pursues an anti-aesthetic and ethic artistic process. He?s using mainly three different strategies; reasoning through text, composing for ensemble, and solo improvising on the saxophone. Through composing the piece for 12 musicians Trästolen, Jutterström tries to erase himself and his taste from the music. In that endeavor he looks to physics as a catalyst.

When anyone acquires control over a listed company the mandatory bid rule is triggered. This means that the person who acquires the control has to make an offer to buy the remaining shares in the company. The purpose of the rule is to protect the minority shareholders from the buyers. This rule has been considered to be burdensome and thus it is followed by an exemption rule which under some special circumstances may make the mandatory bid rule void. The purpose of this thesis is to analyze if the exemptions given by the Swedish securities council (in Swedish Aktiemarknadsnämnden) are in accordance with the purpose of the mandatory bid rule and if a review of these rules are needed.To answer the purpose, the Swedish securities councils statements has been analyzed, to determinate if the exemptions are in accordance with the purpose of the mandatory bid rule.

There are no set guidelines on how to interpret the criteria?s in the adjustment rule within the meaning of the companies act. The criteria?s are not discussed in literature and the Swedish case law in this area is very limited. A reason for the limited use of the adjustment rule is the slow and very costly process, which does not grantee the outcome of the case.

Not all payments that an employee receives are cash salary, but may also be salary benefits. It should not matter in which form an employee receives payment, taxation shall be equal despite the form of salary. Cash salary as well as salary in benefits are covered by a general rule in the Swedish Tax Law and shall therefore be taxed when they have a connection to the work performed. There are exemptions to the general rule as some benefits are tax free. In general, taxation shall be easy to foresee.   The legal rules that are treated in this thesis have a general meaning.

This comparative case study, which is based on a most similar system design,investigates why the Chávez government has attained a lower degree of democracy than the Kirchner and the Lula governments. In order to develop asupplementary theory about why governments in general achieve various degrees of democracy I compare these governments and examine what policies that differ them and why. My results show that these governments? policies differ concerning the rule of law, militarization, and negotiations with economic groups and anti-regime parts of civil society. I have found numerous answers to why some of these governments (and governments in general) have democratic policies within these four areas and why some do not.

This essay studies how advertisements in various anti-smoking campaigns can influence and persuade by using anti-logos as counter-arguments to the tobacco industry's logos. In contrast to tobacco advertising arguments such as freedom (logos), pleasure (pathos) and trademark (ethos) the anti-smoking campaigns create anti-logos arguments with various connotations such as repulsive pictures and sexual implications to influence groups of people not to start smoking or to quit smoking.Advertisement of tobacco does not exist nowadays due to legal restrictions in the western world; however several decades of myths created in the consumer consciousness still exist. Thus one can speak of a tobacco advertising ideology that exists and the various anti-smoking campaigns trying to change that ideology.The purpose of anti-smoking campaigns is to conduct a kategoria of myth that tobacco advertisement has created over the years. Anti smoking organizations do this by creating a new ideology to affect consumer?s attitude toward smoking and the tobacco myth with an anti-myth.

Racial discrimination is a highly topical and burning issue, of special interest in working life. Most researchers agree on that discrimination is a problem in the Swedish labour market. To counteract the ongoing discrimination, a new Anti-Discrimination Act was founded in 1999. The Racial Discrimination Act although appears to be ineffective on the basis of legal usage. Of all the legal cases about racial discrimination in the labour market, there has only been one sentence of guilty stated by the Swedish Labour Court.

The swedish rule concerning the treatment of employee stock-options have changed and the new wording of the rule will be applicable for the first time in 2010. The previous wording of the rule stated that the employee shall be taxed for the stock-option when moving abroad, even if the option is not exercised. The Swedish Skatteverket and Regeringsrätten have found that this rule is in conflict with the free movement of persons within the European Union. The new wording of the rule states that the employee shall be taxed when the option is excercised, no matter where the employee is situated. A state`s right of taxation of a stock-option determines wheter and to what extent the employee stock-otion derives from that state..

Abstrakt All around the world there are a lots of people that suffers from chronic pain. One great factor for the devolopment of chronic pain is the phenomen fear-avoidance/kinesophobia that appear to have negative effects on rehabilitation of chronic painproblems. The aim of the present study was to describe and identify how patient that took part in a rehabilitationprogram in year 2004 and 2005 with focus on behaviourchanges estimate their fear-avoidance/kinesophobia and examine if there was any changes estimate fear-avoidance/kinesophobia respectivly before and after and respecivly before and 12 month after the rehabilitationcourse. The study had a describing prospecitive design. Data was collected by the Swedish version of Tampascale for kinesophobia.

In recent years, the possibility to deduct expenses for research and development (R&D) has been interpreted narrowly. As a response, the Income Tax Act chapter 16, section 9 (the R&D-rule) was amended to increase the possibility to deduct R&D of more general character. The purpose of this thesis is to determine the meaning of the R&D-rule to be able to decide if the amendment is an extension of the deductibility and whether this amendment can be considered adequate.According to the R&D-rule, the recipient of the grant needs to conduct R&D activity and there needs to be a sufficient connection between the R&D activity and the company to be allowed deduction. The difficulty in applying the R&D-rule is mainly when the research is conducted outside the company and the aim of the research is not to solve the company?s specific problem.The connection between the R&D-activity and the company needs to be reasonable. This means that only R&D-activity that falls completely outside the company?s activities should be excluded from deductibility.

The aim of this investigation was to assess if there was a correlation between touch avoidance and hierarchical position, perceived degradation, number of years spent in jail and age amongst men at a correctional institution. In addition, a possible correlation between hierarchical position and the amount of perceived degrading treatment was also explored. In the collection of the data a questionnaire containing 27 open and closed answer alternatives was utilized. A multiple regressional analysis was conducted to find possible correlations between touch avoidance and the other underlying variables. Also an independent t-test explored the possible effects of the control variables: place of birth and girlfriend.

Syftet med denna enkätstudie var att jämföra två olika förklaringsmodeller för tinnitusbesvär; fear avoidance och acceptans. Förutom att undersöka sambanden till tinnitusbesvär, testades även modellerna mot utfallsmåtten tinnitusvigilans och livskvalitet. Då nivå av depression och ångest är kända prediktorer för tinnitusbesvär, användes de som kontrollvariabler. Även processerna mindfulness och värderad riktning testades. Deltagare i studien var 362 patienter med tinnitus som någon gång mellan åren 2004-2011 varit i kontakt med Öronkliniken Hörselvården vid universitetssjukhuset i Linköping.

This essay studies how advertisements in various anti-smoking campaigns can influence and persuade by using anti-logos as counter-arguments to the tobacco industry's logos. In contrast to tobacco advertising arguments such as freedom (logos), pleasure (pathos) and trademark (ethos) the anti-smoking campaigns create anti-logos arguments with various connotations such as repulsive pictures and sexual implications to influence groups of people not to start smoking or to quit smoking.Advertisement of tobacco does not exist nowadays due to legal restrictions in the western world; however several decades of myths created in the consumer consciousness still exist. Thus one can speak of a tobacco advertising ideology that exists and the various anti-smoking campaigns trying to change that ideology.The purpose of anti-smoking campaigns is to conduct a kategoria of myth that tobacco advertisement has created over the years. Anti smoking organizations do this by creating a new ideology to affect consumer?s attitude toward smoking and the tobacco myth with an anti-myth.