Search Results

1 - 10 of 22 items :

  • European Union x
  • Public Finance and Fiscal Theory x
  • Tax and Accounting Law x
  • Business Law x
Clear All
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

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

the European Legal Method(s) and the Interpretational Style of the Court of Justice of the European Union in European Legal Method – Paradoxes and Revitalisation (U. Neergard et al . eds., DJØF Publishing 2011), at p. 104-105. In this context, attention will be devoted to analyzing the PE concept defined in Article 5 of the OECD Model with Commentary as many PE provisions in bilateral tax treaties as well as in domestic law rely on the OECD definition. Cf. J. Sasseville & A. Skaar, General Report in 94a Cahiers de droit fiscal international (International

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

, John and Gregory Morris, “Corporate social responsibility and tax avoidance: A comment and reflection”, Accounting Forum , 2013, 37(1), 1-14; Jenkins, Rhys & Peter Newell, “CSR, Tax and Development”, Third World Quarterly , 2013, 34(3), 378-396; Cerioni, Luca, “International Tax Planning and Corporate Social Responsibility (CSR): Crucial Issues and a Proposed Assessment in the European Union Context”, European Business Law Review , 2014, 25(6), 845–875; Fisher, Jasmine M., “Fairer Shores: Tax Havens, Tax Avoidance, and Corporate Social Responsibility”, Boston

Open access
Eliminating the secondary earner bias. Policy lessons from the introduction of partial individual taxation in Sweden in 1971

issue was discussed ( MTEESS 2016 ). In this paper, we will study the different elements included in the Swedish partial individual taxation reform in 1971 to identify the policy lessons this reform has for contemporary tax policy in the European Union member states. We will argue that one of the most important policy lessons from the Swedish experience is that a shift to individual taxation cannot be limited to technical changes in the tax system. It also needs to be elaborated within a family and social policy context that recognizes the correlation between women

Open access
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.

Open access
Reforming capital gains taxation of intercorporate share realizations : a law and economics approach from a Nordic perspective

dynamics of the international economics. The comparative aspects and results presented in this article are mostly based on the recent results of Anu Torkkeli’s doctoral thesis (June 2016, Hanken publications) Structuring Corporate Capital Gains Tax System in the European Union - A Comparative Finnish Perspective Anu Torkkeli, Publications of Hanken School of Economics, Nr 296, Helsinki 2016. The academic opponent of Torkkeli’s thesis was professor Mattias Dahlberg from Uppsala. The co-author of this NTJ-article, professor Matti Kukkonen has worked as Anu Torkkeli

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

. Interest Allocation Rules, Financing Patterns, and the Operations of U.S. Multinationals. In: Feldstein M., Hines jr. J.R. and Hubbard R.G. (eds), The Effects of Taxation on Multinational Corporations. University of Chicago Press, 277-312. Gouthière B., 2005. A Comparative Study of the Thin Capitalization Rules in the Member States of the European Union and Certain Other Countries. European Taxation 45, 367-451. Haufler A. and Runkel M., 2012. Firms’ Financial Choices and Thin- Capitalization Rules under Corporate Tax Competition. European

Open access
Tax or social security contribution, a world of difference?

social security systems, whereby the rule of non-aggregation of relevant laws would not be applicable to the tax. In this regard, the European Court of Justice has ruled that the national social security schemes in their entirety are subject to the application of the rules of the European Union transnational coordination law. Here, the determining factor is the direct and sufficiently relevant coherence that a particular provision tax provision has to demonstrate with the laws that fall under the material scope of EU Regulation No. 1408/71 and now EU Regulation No. 883

Open access
Corporate tax in an international environment – Problems and possible remedies

.P. (2002), Cash flow taxes in an open economy. CEPR Discussion Paper 3401, London. Brøchner J., Jensen J., Svensson P. and Sørensen P.B. (2006), The Dilemmas of Tax Coordination in the Enlarged European Union. CESifo Working Paper No. 1859, Munich. Bucovetsky S. (1991), Asymmetric tax competition. Journal of Urban Economics 30, 167-181. Büttner T., Overesch M., Schreiber U. and Wamser G. (2012), The Impact of Thin-Capialization Rules on the Capital Structure of Multinational Firms. Journal of Public Economics 96, 930

Open access
Good Tax Governance: A Matter of Moral Responsibility and Transparency

relation to others (see §2 - §4). CSR and ethical business making as such are already on the agendas of many corporations, but also of law and policy framing institutions. For example, since the introduction of EU Directive 2006/46/EC (2006), all the listed companies in the European Union are obliged to publish their CSR statements. What such statements exactly should entail is unclear. Therefore, the question still remains as to whether these published strategies can also be regarded as acting socially responsible. In our opinion, a corporation engaging in CSR can

Open access