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The Emergence of Denmark’s Tax Treaty Network — A Historical View

where the place of effective management was located. A specific provision dealt with diplomatic and consular representatives. Moreover, it was determined that even though the treaty with Sweden was based on the principle that only the domicile state or the source state should be able to impose taxes on a given income, the domicile state was entitled to make the tax calculations on the basis of the full income ( i . e ., relief after the method exemption with progression). It is interesting to see that the first genuine Danish tax treaty contained numerous principles

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The Nordic model: 25 years of drawing the line between earned and capital income in Finland

. 2 The tax policy background of the dualistic income tax system 2.1 Finland followed the other Nordic countries In many countries, the capital gains are separately taxed, or a different mechanism is applied for determining and calculating them (see, e . g ., Pistone 2016 ). However, the full differentiation and separation of all capital income of natural persons is characteristic of the Nordic countries. The development began with the 1987 tax reform in Denmark, where progression was almost completely abolished in the taxation of capital income. Sweden

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

, proportional taxation or partial or complete progression The effect of ownership time to the tax rate Tax treatment of undistributed ( distributed ) profit of a limited liability company: whether undistributed profit ( hidden increase in value of shares ) is under double taxation Tax neutrality of tax treatment of different types of capital income and taxation of changes in value of different taxpayers ( individuals / corporate bodies ) Deductibility of loss: deduction forward or backwards , limitations . 1.3 Capital gains tax issues from law

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