References Burgers, I., & Mosquera, I. (2017). Corporate Taxation and BEPS: A Fair Slice for Developing Countries? Erasmus Law Review, 1 (8), 29-47. https://doi.org/10.5553/ELR.000077 Cockfield, A. (2014, September 15). BEPS and Global Digital Taxation. Tax Notes International, 75 (11), 933-940. Cordewener, A. (2017). Anti-Abuse Measures in the Area of Direct Taxation: Towards Converging Standards under Treaty Freedoms and EU Directives? EC Tax Review, 2 , 60-66. Durst, M. (2014). Beyond BEPS: A Tax Policy Agenda for Developing Countries. Institute of
1 Introduction Some 100 states have participated in the development of a new multilateral convention designed for the swift implementation of the tax-treaty-related measures agreed upon as part of the Organization for Economic Cooperation and Development’s (OECD) so-called Base Erosion and Profit Shifting (BEPS) Project. The convention is entitled “The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting” and is often referred to as the Multilateral Instrument (MLI). A text was agreed upon in November 2016
1 Introduction In recent years, legislation on controlled foreign companies (CFC legislation) has gained renewed attention from policy makers, academics, and practitioners around the world, as this kind of legislation can play an important role when addressing the much-debated issues related to aggressive tax planning by multinational enterprises. Accordingly, in their recent efforts to address base erosion and profit shifting (BEPS), both the OECD/G20 and the European Commission have acknowledged the importance of introducing CFC legislation, or tightening CFC
regard, it should also be noted that the amendments to the PE definition prescribed in the OECD/G20 BEPS report on Action 7, and incorporated into the 2017 version of the OECD Model Tax Convention on Income and Capital (21 November 2017) with commentaries, may have pushed this question further up the agenda. Cf. OECD/G20, Preventing the Artificial Avoidance of Permanent Establishment – Action 7: Final Report (OECD 2015). The article will not address other BEPS-related issues concerning private equity funds, including the issues regarding treaty entitlement of Non
Although globalization has contributed immensely to growth and prosperity around the world, it is a growing challenge for tax policy makers. Globalization and greater mobility of tax bases increase the relative importance of taxes in corporations’ investment decisions. The combination of highly mobile capital, inadequacies in existing tax laws and a total change of international business environment have led to the fundamental problem in international tax law labeled by the OECD as the problem of BEPS (Base Erosion and Profit Shifting), along with severe competition among countries to attract investments and business activities. These challenges are the topic for the 2014 seminar of the Nordic Tax Research Council. Based on the Nordic national reports we discuss these challenges
erosion and profit-shifting (BEPS) initiative [ 9 , 39 , 40 ]. The primary purpose of this exercise was to identify the levels of such tax avoidance and the locations used to pursue it and to use the resulting transparency to encourage local tax authorities to effectively police and recover taxes that should legitimately fall due within their jurisdictions. Among the measures adopted as a part of the BEPS process was a form of CBCR [ 40 ]. This was explicitly derived from recommendations made by civil society groups [ 33 , 37 ]. In this context, it is important to
Although radiocarbon (14C) dating, uranium-series dating, and optically stimulated luminescence (OSL) dating have been conducted for Upper Palaeolithic sites in the Nihewan Basin, northern China, there is room for constructing a detailed chronological framework. In this study, loess sediments collected from two Upper Palaeolithic sites, Youfang site and Hutouliang site, were dated using the single-aliquot regenerative-dose (SAR) OSL protocol. OSL measurements for palaeodoses estimation used fine-grained quartz samples extracted from loess. OSL dating results were obtained as 10–17 ka. These OSL ages were consistent with the related stratigraphy of Palaeolithic sites, archaeological evidence and independent 14C ages.
Several studies have used luminescence dating to investigate sand mobilization activity in extreme western areas and the southern margin of the Thar Desert, India. However, room exists for a chronology of sand profiles for the northern margins of the Thar Desert. The Ghaggar River flood plain at Rajasthan, northwestern India, in the northern margin of the Thar Desert, is bordered by sand dunes. Elucidation of the environmental changes of the Ghaggar Basin requires knowledge of many aspects of sand dune formation.
We measured optically stimulated luminescence (OSL) using the single aliquot regenerative-dose (SAR) protocol for sand of eight palaeo-dunes and two flood silts of both sides of the present Ghaggar Basin and Chautang Basin flood plains. Their OSL ages were obtained respectively, as 15–10 ka or 5 ka, and 9–8 ka. Results of this study reinforce the hypothesis that sand dune deposition had started or had already been completed by 15‐10 ka. Aeolian deposition was subdued by enhanced moisture during 9–8 ka. Our interpretation is that, at least since 5 ka, the scale of the flood plain of the Ghaggar River has remained equivalent to that of the present day.
We determined the eruption age of basaltic rocks by application of thermoluminescence (TL) method, which is often used for TL dating, to quartz. Mafic magma only rarely includes quartz because of their mutual disequilibration. The basaltic lavas reported herein include quartz as xenocrysts, as corroborated by their rounded or anhedral shape.
The basaltic lava used for this study is from the Oninomi monogenetic volcano in northern Kyushu, Japan. The volcano eruption was estimated as occurring 7.3–29 ka because the lava exists between two widespread tephras: Aira-Tanzawa ash (26–29 ka) and Kikai-Akahoya ash (7.3 ka). We succeed-ed in collecting ca. 200 mg of quartz by decomposition of 30 kg of the lava samples. TL measurements for the lava indicate the eruption age as 15.8 ± 2.5 ka, which is fairly consistent with the stratigraphical estimation. Although the TL method has played a considerable part in constraining the timescale of Quaternary events, its application has been limited to silicic samples. The present result demonstrates the availability of quartz for dating even of mafic rock.
Nordic Tax Journal 2014:2
NSFR Seminar 2014 –
National Report for Sweden
Abstract: This article aims to give an overview of the rules concerning taxation of
companies in Sweden and of trends in the taxation of companies that have been
evident in the last few years. It focuses in particular on issues that are connected
with the so-called BEPS discussion, for instance interest deduction limitations,
CFC rules, general anti-avoidance rules and other rules intended to protect the na-
tional tax base. It also sets out to