methodology will increase significantly administrative work.
The theoretical (and practical) major problem issues related to the taxation of changes in value can be listed as follows:
The extent of the definition of income: whether changes in value are taxable
Spreading of taxation of changes in value: whether changes in value are taxed based on accrual or realization
Taxation method of inflation component of change in value: whether taxation is applied to nominal or real change in value
Tax systems of changes in value: independent taxation
reflections on the Nordic experience and its implications for the study of comparative tax law and the globalization problem.
Throughout the article, I will refer to the “Nordic region,” “Norden,” and (less frequently) “Scandinavia” as a single unit, typically including all of the countries above together with smaller entities (e.g., the Faroe Islands) that share basic characteristics with it. I recognize that this is a fiction, because the countries involved vary considerably in tax and nontax policy, and that Scandinavia in particular is an inaccurate, confusing word
in this regard, in our respective countries.
2 The Decisive Moment
In many cases, the question of where the decisive moment lies has a more or less obvious answer. Sometimes, however, difficulties arise. Further, in some cases, the obvious answer de lege lata may not be the most materially appropriate de lege ferenda , for example, from the perspective of foreseeability. If, due to uncertainties regarding the decisive moment, it is not clear when something should or should not be the case, several significant problems arise. For example
to qualified work (Proposition [prop.] 2009/10:175 [government bill] (swed.). However, efficient value-creation requires that the taxpayers have the chance to choose how and where to meet and that the meetings are transparent and in accordance with information given and standard procedures. This means that the taxpayers should be offered the chance to solve their problems electronically or through a face-to-face meeting and that they are informed about the possibility. Taxpayers should get the same answers to their questions regardless of meeting format and the
to analyze the MLI in light of rule complexity and legal uncertainty.
Tax complexity and similar terms can mean many different things and may often, depending on how they are defined, include the way taxpayers perform necessary activities in completing their tax compliance tasks ( Pedersen 2012 ). In Untangling the Income Tax , David Bradford (1986) distinguishes three types of tax complexity: compliance complexity, transactional complexity, and rule complexity. Compliance complexity refers to the problems faced by the taxpayer in tasks such as keeping
solve all problems. Consequently, the development of this impressive treaty network aptly has been called a ”flawed miracle” ( Avi-Yonah 1996 ).
International juridical double taxation can generally be defined as the imposition of comparable taxes in two (or more) states on the same taxpayer in respect of the same subject matter and for identical periods. Cf. the introduction to the OECD Model Tax Convention (2014) , para. 1. In contrast, the so-called economic double taxation occurs in when the same income is taxed in the hands of (two) different tax subjects
representatives. This observation does not mean, however, that the company cannot formulate, as a part of its corporate culture, some kind of collective perceptionsof right and wrong. Similarly, institutional investors as a legal entity do not have moral considerations, but the investment managers and portfolio managers as natural persons may have.
The relationship between law and morality is a classic legal philosophy issue. From the perspectives of legal history and philosophy, the question is also about the relationship between natural law and legal positivism. Further
applying for joint taxation of spouses creates disincentives for the labor supply of the secondary earner, and the problem escalates with a more progressive structure of the income tax system. Transferable tax credits, tax credits based on the family unit, and eligibility and means-testing of social benefits based on household income, are also part of the negative incentives for secondary earners’ labor market participation ( Rastrigina and Verashchagina 2015 , 9). Even if exemptions and deductions that are meant to improve the conditions for women´s work have been
their families as having special standing ( Bloomfield 2007 , 3). A moral point of view does not require that individuals behave in an altruistic way, but rather that they see their personal interests, objectives and ideals in relation to those of other individuals in society.
Thus, morality is about how one ought to act. Studying ethics concerns the philosophical inquiry, for example, to obtain clarity on moral problems and to resolve them in an ethically satisfactory way ( Callahan 1988 , 7). Ethics studies morality ( De George 1999 , 19). The philosophical study
on the current question ( Bokföringsnämnden 2012 ; EFRAG 2013).
The subjective prerequisite in the Tax Avoidance Act
At first glance, it may be assumed that the notion of objectivity that has come to characterize the perceptionof the gift concept in Swedish law also characterizes the view toward subjective prerequisites in general in tax law. But although this is undoubtedly a common view among tax lawyers, it is far from sure, and is one of the questions investigated in this paper. In principle, this view means that, in order to determine the taxpayer