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BEPS Policy Failure—The Case of EU Country-By-Country Reporting1

al . [ 13 ] and Garcia Bernardo et al . [ 22 ]. The point is that there is not error on display here, but that there is instead a lack of precision in defining the required disclosures that has given rise to the preparation of inconsistent data that are undermined the objective of this process, which was to reliably indicate whether profit-shifting was taking place, where and by whom on a consistent and comparable basis. Requiring disclosure of tax provided in both the profit and the loss account and paid as shown by the cash flow, and the reconciliation of other

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Basic Income—an early Icelandic experiment**

of development of sectors other than fisheries and agriculture slowed the recovery of economy, GDP contracted by 1.3% in 1967 and by 5.5% in 1969 ( Hagstofa Íslands 2019a ,b). In 1970, Iceland joined the European Free Trade Association (EFTA), and the national system of taxes and duties had to be revised. The then-existing tax system had been adapted to the needs of strong special interest groups, especially those involved in fisheries and agriculture. Icelandic agriculture based its existence largely on subventions. Fishing firms paid considerably lower taxes

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Permanent Establishment for Investors in Private Equity Funds—A Legal Analysis in Light of the Changes to the OECD Model (2017)

structure of different private equity funds varies, a basic version of a typical fund structure can be outlined. Often, a private equity firm is legally structured as a limited partnership owned jointly by a general partner and a number of limited partners (the investors). Often, the general partner is an entity owned by the fund managers. The fund managers or entities owned by the fund managers receive annual management fees, typically amounting to 1–3% of the fund’s assets, for this work (sometimes also one or several advisory companies are part of the overall structure

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The Decisive Moment(s or periods) in the Application of Income Tax Rules and the Importance of Events Thereafter – a Swedish, Norwegian and Finnish Perspective and Comparison

shown in Krzymowska A, Skattepliktiga överlåtelser i inkomstslaget kapital, Jure, 2018. Here, firstly, the principle for the general decisive moment for certain capital gains is presented, and then, secondly, the decisive moment in more concrete, individual cases is analyzed. This is important to keep in mind. 2.4 Explicit Rules Sometimes, the principle for the decisive moment follows, more or less directly, from the very letter of the respective tax rule, or from its close context. An example of this is the Swedish inventory valuation, where 18 Ch. 13 § 2

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Acceptable levels of tax risk as a metric of corporate tax responsibility: theory, and a survey of practice

this category in tax industry discourse; for example, the authors of a blog post on the PwC website wrote as follows: So where does tax risk originate? Tax risk isn’t typically created within the tax function; it happens earlier in the value chain, with data, and with people making decisions at the front end of the organisation without sufficient understanding of the tax consequences. Giovanni Bracco and Robert Gooding, ‘Tax risk: Why tax and risk need to speak the same language’,, 13 June 2016, available at

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The Nordea Bank Denmark Case (C-48/13)


This paper reports on an investigation of a recent decision by the European Court of Justice (ECJ) in case C-48/13, Nordea Bank Denmark, concerning the Danish rules for reincorporation of losses from permanent establishments situated in European Union/ European Economic Area (EU/EEA) member states other than Denmark. The article includes comments on various EU tax law aspects of the case - namely the restriction test applied by the ECJ, the justifications brought forward by the intervening governments and the question of proportionality - and examines the consequences of the Danish tax law going forward.

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Recent developments in Corporate Taxation in Sweden

, Swedish Network for European Studies in Economics and Business Berg, C.J. Hansen and P. Sehlin (2004). The financial accelerator and corporate investment, Economic Review, 2: pp. 23-46. Bernanke, B., M. Gertler och S. Gilchrist (1996), The Financial Accelerator and the Flight to Quality”, Review of Economics and Statistics, 78, 1-15. Bernanke, B., M. Gertler och S. Gilchrist (1999), “The Financial Accelerator in a Quantitative Business Cycle Framework”, i Taylor, J. B. och M. Woodford (red.), Handbook of Macroeconomics, vol. 1(3

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Corporate Social Responsibility, Taxation and Aggressive Tax Planning

Journal 1990, pp. 201-262. Musgrave, Richard A. - Musgrave, Peggy B.: Inter-nation equity. In "Modern Fiscal Issues; Essays in Honor of Carl S. Shoup", University of Toronto Press 1972, pp. 63-85. Mönkkönen, Mauri: Mäntän historia 1948-1992. Gummerus Kirjapaino Oy, Jyväskylä 1998. OECD: Guidelines for Multinational Enterprises 2011 Edition. OECD: Addressing Base Erosion and Profit Shifting, OECD Publishing 2013. Webpage: (13.12.2013). (OECD 2013a

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Tax or social security contribution, a world of difference?

. 1, last amended by Regulation (EC) No. 2017/492, OJ L 76, p. 13. are applicable; this is applicable also to Denmark, Finland and Sweden, which are EU Member States. Since 1 June 2012, the regulations are also applicable to Iceland and Norway, which are EFTA-countries. I limit myself here to the collection of social security contributions and do not treat the issue of social security benefits payment. A separate Nordic Convention on Social Security (2012) applies with respect to social security. The Convention entered into force on 1 May 2014 (Denmark, Finland

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Debt Shifting and Thin-Capitalization Rules – German Experience and Alternative Approaches

. Buslei H. and Simmler M., 2012. The Impact of Introducing an Interest Barrier - Evidence from the German Corporation Tax Reform 2008. DIW Discussion Papers 1215, Berlin. Deloitte 2014. Guide to Controlled Foreign Company Regimes. Accessed online at De Mooij R.A., 2011. Tax Biases to Debt Finance: Assessing the Problem, Finding Solutions. IMF Staff Discussion Note SDN/11/11, Washington DC. De

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