The aim of this paper is to investigate International Loss Compensation. The paper also assesses in what way Sweden could use the recent developments in Community law to increase competiveness by tax measures others than lowering taxes…
Contents
1. INTRODUCTION
1.1. AIM AND DELIMITATION
2. BASIC PRINCIPLES OF SWEDISH INCOME TAX LAW
2.1. GROUP TAXATION
3. GROUP TAXATION, INTERNATIONAL ASPECTS
3.1. INTERNAL LAW
3.2. COMMUNITY LAW
3.2.1. Community Law in General
3.2.2. Free Movement
3.2.2.1. Freedom of Establishment
3.2.2.2 Free Movement of Capital and Payments
3.2.2.3. Limitations and the Rule of Reason Doctrine
3.2.2.4. Convergence Between the Freedoms
4. GROUP CONTRIBUTION TO ANOTHER MEMBER STATE
4.1. INTRODUCTION
4.2. SCOPE OF THE FREEDOM OF ESTABLISHMENT
4.3. MARKS & SPENCER
4.3.1. Application of Community Law
4.3.2. Is There a Restriction?
4.3.3. Rules of Reason
4.4. APPLYING MARKS & SPENCER ON THE SWEDISH GROUP CONTRIBUTION SYSTEM
4.4.1. Comparison Between the British and Swedish Loss Relief Systems
4.4.2. Carrying the Contribution
4.4.3. Direction of Group Contribution
4.4.4. Calculation of the Losses
4.4.5. Grounds for Justification
5. GROUP CONTRIBUTION TO THIRD COUNTRIES
5.1. IS THE NATIONAL LIMITATION RESTRICTING THE FREE MOVEMENT OF CAPITAL AS WELL?
5.2. SPECIAL EXCEPTIONS IN TAX MATTERS REGARDING THE FREE MOVEMENT OF CAPITAL
5.3. SPECIAL EXCEPTIONS TO THE ERGA OMNES PRINCIPLE IN FORM OF A STAND STILL CLAUSE
5.3.1. Introduction
5.3.2. Application of Any Restriction to Third Countries….
6. RIGHT TO INTERNATIONAL GROUP CONTRIBUTION……
Author: Oskar Fredriksson
Source: Stockholm School of Economics