family, British law (and not Indian or Australian law) is the parent jurisdiction ( Zweigert and Kötz (1998) ). This idea of using legal families as a tool for comparative studies is based upon the assumption that the material of a comparison might be reduced by way of generalization ( Rainer (2010) ). Comparing all jurisdictions in the world would be impossible or at least very difficult. It would therefore simplify the working process of a comparative study if a few representative jurisdictions could be identified.
The classification and division into legal
use the term as system thinking. The view of lean has developed and changed over the years and it can be difficult to know exactly what the concept stands for ( Innovationsrådet (2012) ). 9 Modig and Åhlström divide lean into three levels 1. Lean as a philosophy, culture and values etc. 2. Lean as a means of improvement, quality assurance system, production system etc., and 3. Lean as metods, tools, elimination of waste etc. See Modig, Niklas and Åhlström, Pär, Vad är Lean?. It could be described as a “travelling idea” ( Quist 2003 ). Lean can be
travaux préparatoires as a tool for the interpretation of Swedish law, until the 1990s, when it was followed by a more critical approach to contents that could be in conflict with unambiguous statutory wording ( Tjernberg (2003) ). In some cases, however, the Supreme Administrative Court has recently disregarded specific isolated wording in the legislation explicitly, in favor of a systematic interpretation that is closer to the spirit of the travaux préparatoires (see Rydin (2014) ; Tjernberg (2015) . In Finland, great emphasis is also placed on the principle of
. Nevertheless, the terms remain prominent in policy discourse, and indeed, the lumping of the Nordic countries together has become a powerful tool in marketing (some would say falsely marketing) the Nordic model outside the region. Readers un-comfortable with these terms should feel free to substitute “the so-called Nordic countries,” “Sweden and its neighbors,” or “the countries lying north of Germany, west of Russia, and somewhere northeast of Great Britain” at appropriate points in the text.
The Nordic Model and Its (Surprisingly) Persistent Appeal
The concept of
governments with means for counteracting BEPS.
After two years, the measures developed in the course of the work on BEPS were presented in the form of reports on each of the 15 actions, accompanied by an Explanatory Statement—the so-called Final BEPS Package. According to the OECD, the Final BEPS Package gives countries and economies the required tools to ensure that profits are taxed where economic activities generating profits are performed and where value is created, while simultaneously providing businesses with greater certainty by reducing disputes over the
Axel Hilling, Niklas Sandell and Anders Vilhelmsson
those touched by the law and those not touched by it. We also maintain that income tax has a symbolic importance, as it is imposed on all members of a society. Income tax legislation is a powerful tool to demonstrate initiatives in response to highly charged political questions.
This article has shown that the incentive for taking initiatives that are visible to the public sometimes comes at the expense of the quality of laws and their supervision. In 2006, rules were introduced enabling lucrative income shifting using shares acquired on a naked-in–naked-out basis
term close company is used in English in International tax law for small limited companies were the owners are usually active in the business.” The so-called threshold amount is a tool used to deem income from a close company either as earned or capital income. When calculating the threshold amount, the basis, according to Ch. 57, Sec. 12, is reduced with such contributions that were made for a purpose other than the permanent provision of capital to the company.
When calculating the year’s threshold amount, it is beneficial for the shareholders if their
becomes possible to combine income equalization with high profits in the most dynamic firms. In Swedish:”... blir iédn om en ‘kapitalism utan kapitalister’ annars till det sammanhållande kittet mellan kollektivismen och marknadens dynamik. På detta sätt kan kapitalismen äreräddas - samtidigt som det inte finns plats för starka ägare eller kaptialister. Inkomstutjämning kan ske samtidigt som de mest dynamiska företagen tillåts göra stora vinster.”
A key tool in reaching this goal was to design the tax system in a manner that fostered this development. The political
, the Directorate questioned whether the companies actually were “cooperating companies” and whether the sole intention of registering as a VAT group was to obtain relief from paying VAT on costs connected with the acquisition of the shares.
The case gives a discreet indication of potential tax avoidance aspects connected with the criteria for cooperating companies. As such, the criteria for “cooperating companies” may be seen as a tool for testing tax avoidance in connection with VAT groups (see Section 7.1 ). In this author’s opinion, the cooperative criteria
territorialisierend dar: Sie blieben die wichtigste Territorialeinteilung Preußens bis zum Ende des Staates 1947. Analog und doch völlig verschieden gestaltete sich eine ›provinzielle Staatsbildung‹ in den Niederlanden. Stefan Couperus, Harm Kaal, Nico Randeraad und Paul van Trigt zeigen in ihrem Beitrag am Beispiel Südhollands, wie sich Provinzialverwaltungen an der Staatsbildung beteiligten, indem sie sich als administrative Institutionen des neuen Einheitsstaates erfanden und mittels ›little tools of knowledge‹ Zu diesem Konzept vgl. Peter Becker / William Clark: »Introduction