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Nordic Tax Journal 2014:1 Roger Persson Österman 152 Berglund, M. 2013. Avräkningsmetoden – En skatterättslig studie om und- vikande av internationell dubbelbeskattning. Uppsala: Iustus Förlag Book Reviews Roger Persson Österman Keywords: International tax law, transnational tax law, credit of foreign tax 1. Inledning En av mina f.d. kollegor på EY (f.d Ernst & Young) menade på att Martin Berglunds avhandling var den bästa på flera decennier. Jag kunde genast ställa saken tillrätta, genom det blygsamma påpekandet att min egen avhandling kom 1997. Här

Abstract

This paper discusses the harmful tax practices of multinational enterprises (MNEs) and the fight of international organizations against them. We focus on the anti-tax base erosion and profit shifting project (anti-BEPS project) of the Organisation for Economic Co-operation and Development (OECD), namely its 15 actions, which we present in the first part of the paper, using descriptive and analytical methods. In the second part, we use critical and synthetic methods to assess how the selected aspects of multinational business will be impacted with described actions. Our conclusions show that MNEs will have to adapt their business structures and plans according to new tax regulations, which will also lower their profit levels due to unavailability of established harmful tax structures for lowering their tax bases. At the same time, our results indicate that the legal approach in introducing new measures on the subject field, lead to legal uncertainty in tax matters. Due to the scope of analysed problems, it was impossible to introduce individual problems in depth; however, we provide readers with the general characteristics and goals of introduced actions that are necessary for understanding our evaluation of their impact on certain fields of international business. Our paper contributes to literature and practice, as it provides general insight into recent and important international tax law developments that enterprises will have to consider when doing business across borders.

in future Nordic tax re- search because of its comprehensiveness. The second re- view is about a bookwritten in Swedish: Momsfri sjukvård (The VAT exemption for health care). This volume dis- cusses a topical issue and presents convincing recommen- dations for changes in the Swedish VAT legislation. Fi- nally, the Danish book International Skatteret, i et dansk perspektiv (International Tax Law, in a Danish perspec- tive) is presented ashighly recommended literature for stu- dents andpractitioners in the field of international tax law. This volume discusses and

with an increasing focus on international tax law, BEPS, and the inclusion of a GAAR in EU’s Parent-Subsidiary Directive, the subject seems very relevant and well chosen. As a reader, one expects to learn more about how to maneuver in this area. In Chapter 1, the author introduces the subject that is to be investigated. The starting point is a globalized world with an explosive increase in cross-border transactions. Having set that scene, the author raises the question whether a GAAR loses its effect if the income in question is covered by a DTA. On the one hand, a

Abstract

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

), Fundamentarea convențiilor de evitare a dublei impuneri fiscale internaționale în România – o abordare holistică , în Volumul Adaptabilitate, Divergențe și Perspective în Contabilitatea și Fiscalitatea Contemporană, CECCAR Arad, Coordonatori: Mateș D., Cernușca L., Micle, N., Dumiter, F., David, D., Costi, B., Horga, P., Editura Casa Cărții de Știință, Cluj – Napoca, pp. 237 – 258. 5. Maisto, G., (2005), Multilingual Texts and Interpretation of Tax Treaties and EC Tax Law, EC International Tax Law Series Volume 1, IBFD. 6. Panayi, C., (2007), Double Taxation, Tax Treaties

5. References [1] Reimer, E., Rust, A., Klaus Vogel on Double Taxation Conventions – Fourth Edition, Vol. II, Wolters Kluwer Law & Business, 2015. [2] Éva Erdős, Conflicts in the international tax law and answers of the european tax law, Curentul Juridic, Târgu Mureș, Vol.47, 2011, pp. 159-174. [3] Ioan Rus, Eleonora-Laura Avram, Paula Monica Bocicor, Mirela Ruxandra Republic of Moldovan, Evitarea dublei impuneri între România și statele: Ungaria și Bulgaria, Academica Science Journal Studia Series, Tîrgu Mureș, Nr.(3)-2, 2013, pp. 50-57. [4] Brian Caster, After

Press Hasen, David M. 2004. “Tax Law Review.” A realization-based approach to the taxation of financial instruments . Vol. 57, spring. Pages 397-481. Hasen David M. 2004 “Tax Law Review.” A realization-based approach to the taxation of financial instruments 57 spring 397 481 Helminen, Marjaana. 1999. The dividend concept in international tax law: dividend payments between corporate entities . Dissertation thesis. Series on international taxation; no 25. London: Kluwer Law International. Helminen Marjaana 1999 The dividend concept in international tax law: dividend

Taxation – U.S. Taxation of Foreign Persons and Foreign Income Chicago CCH Jiménez, Martín. 2012. “Towards a Homogeneous Theory of Abuse in EU (Direct) Tax Law.” Bulletin of International Tax Law 66 (4/5), 270–92. Jiménez Martín 2012 “Towards a Homogeneous Theory of Abuse in EU (Direct) Tax Law.” Bulletin of International Tax Law 66 4/5 270 92 Kleist, David. 2008. “Någraytterligara kommentarer angåendeförhål-landetmellamskatteavtalenoch intern rätt.” Skattenytt (11), 708– 14. Kleist David 2008 “Någraytterligara kommentarer angåendeförhållandetmellamskatteavtalenoch

OECD Model Tax Conventions on Income and on Capital to express propositions about the proper understanding of tax treaties. From the point of view of the legal justification of such propositions, this practice poses a problem, considering that the legal rele- vance of OECD Commentaries remains an issue of serious contention among international tax law experts. Most im- portant, international tax law experts have long debated the relevance of changes to OECD Commentaries for the purpose of interpreting previously concluded tax treaties.1 Ulf Linderfalk: Professor of