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Betydelsen av bostad och väsentligt inflytande i näringsverksamhet för individens skattemässiga status
In Sweden a person is either unlimited or limited liable to tax. It is important to define this status since the consequence of being unlimited liable to tax according to chapter 3 § 8 Swedish income tax law (1999:1229) is imposed tax on every revenue from Sweden and overseas …
En juridisk analys med fokus på Regeringsrättens tolkning av de svenska koncernbidragsreglernas förenlighet med EG-rätten
… 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 …
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 …
samt bevisningsfrågor till följd av dokumentationskravet
… of transfer pricing have become essential to multinational enterprises and tax administrations. For states it is important that the transfer pricing is correct to defend their tax base. Incorrect transfer pricing can also have dire effect on the enterprises. They run the risk of …
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 …
Rättskällevärdet i förhållande till legalitetspricipen och förutsebarhetens påverkan
Individuals considered as tax residents in Sweden may if they are working abroad for six months alternatively one year be granted a tax exemption concerning the income originating from the work abroad. Short intermissions (kortare avbrott) are permitted without impact on the tax …
En studie om frequent flyer-program och deras effekt på kunderna
… documentation requirements were introduced, and the government began to do tax audits regarding transfer pricing. This thesis examines how the documentation requirements and tax audits affect the application of the arm's length principle. The research consists of nine interviews …
En studie om hur tillämpningen av armlängdsprincipen påverkas av Skatteverkets ökade fokus på internprissättning
… documentation requirements were introduced, and the government began to do tax audits regarding transfer pricing. This thesis examines how the documentation requirements and tax audits affect the application of the arm's length principle. The research consists of nine interviews …
… thesis has as purpose to describe and analyse a decision made be the Swedish tax committee in which it was decided that a cooperative economical associations selling price, which was less than the comparable public bonds market price, would be the focus of a withdrawal tax …
nutida strider, historisk arena
… 14th century it was a common opinion that the King had the legality to impose taxes upon the birkarla men. During the 16th century these two forms of societies more frequently began to run into each other. The state of Sweden perceived the development in the northern parts …
Möjligheten att få både skattesköld och klassning som eget kapital enligt svensk rätt
… sectional study also includes areas such as credit rating, accounting and tax. The thesis concludes that it is possible, under Swedish law, to issue corporate hybrid securities that qualify for both high equity credit and tax deductible interest payments. The use of certain …
Förändringar och marknadsföring på bibliotek, en utvärdering av Skogsbibliotekets "library brand" utifrån studentperspektiv.
… 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 …
Analys av skalbolagsreglerna ur ett tillämpnings- och rättssäkerhetsperspektiv
… a severe problem since the purchaser often has the aim of obtaining undue tax advantages by not paying the tax debt of the company. Historically it has been complicated for the legislator to stop the set-up in an efficient way since the transactions as such are not illegal …
Räntesnurror ur ett kommunalt perspektiv.
… regarding interest deduction limitations was enforced. The aim was to prevent tax structure with interest deductions in a community of interest. The changes meant that intra-group share transfers, which generates an intra-group loan structure, can lead to borrower losing their …
- särskilt vid åtgärder mot främlingsfientlighet inom polisen
… of members of the Swedish police-force. By making an analogy with Swedish tax law an argument can be made that the relationship between labour law sanctions and criminal law punishment for wrongful acts is worth examining, and might not fully be in line with the principle of ne …
