Change search
CiteExportLink to record
Permanent link

Direct link
Cite
Citation style
  • apa
  • ieee
  • modern-language-association-8th-edition
  • vancouver
  • Other style
More styles
Language
  • de-DE
  • en-GB
  • en-US
  • fi-FI
  • nn-NO
  • nn-NB
  • sv-SE
  • Other locale
More languages
Output format
  • html
  • text
  • asciidoc
  • rtf
Corporate form and international taxation of box corporations
Stockholm University, Faculty of Law, Department of Law.
2006 (English)Doctoral thesis, monograph (Other academic)
Abstract [en]

The subject matter of the thesis is new as the phenomenon of the Box Corporation has not been the subject of a specialized investigation from the fiscal perspective before. A foreign subsidiary indirectly owned in a third country jurisdiction is in the thesis classified as a Box Corporation.

The subject of the thesis is primarily to analyze and establish the following connections: the intended corporate objectives and ends and the modus operandi and the means that often require the Box Corporation as a necessary vehicle to attain those ends. The close connections between corporate law and tax law as intended legal results interdependent on one another. The application of the Box Corporation as an important vehicle for international tax planning by Swedish corporate groups on ever increasing competitive international markets and the special tax problems connected to the Box Corporation as it presents serious challenges to the pursuits for a consistent, neutral and undistorted Swedish corporate tax system. The thesis also investigates legislative and regulatory public reactions to the Box Corporation in the ways of CFC tax provisions, of denying tax treaty privileges by Limitation of Benefits clauses and of increasing domestic requirements on reportable transactions and international exchange of information and co-operation.

Place, publisher, year, edition, pages
Stockholm: Acta Universitatis Stockholmiensis, 2006. , 527 p.
Series
Studia juridica Stockholmiensia, ISSN 0562-2840 ; 87
Keyword [en]
International taxation, tax theory, corporations, treaties, group indirect ownership, tax planning, neutrality, exchange of information
National Category
Law (excluding Law and Society)
Identifiers
URN: urn:nbn:se:su:diva-1009ISBN: 91-85445-34-7 (print)OAI: oai:DiVA.org:su-1009DiVA: diva2:189170
Public defence
2006-06-14, hörsal 7, hus D, Universitetsvägen 10, Stockholm, 10:00 (English)
Opponent
Supervisors
Available from: 2006-05-24 Created: 2006-05-24 Last updated: 2012-07-12Bibliographically approved

Open Access in DiVA

fulltext(19491 kB)572 downloads
File information
File name FULLTEXT01.pdfFile size 19491 kBChecksum SHA-1
a2a4992ce52272f153f71eeb0d37d257f6455b2baca8e530bbe4c0660ca746ec9d517c83
Type fulltextMimetype application/pdf

By organisation
Department of Law
Law (excluding Law and Society)

Search outside of DiVA

GoogleGoogle Scholar
Total: 572 downloads
The number of downloads is the sum of all downloads of full texts. It may include eg previous versions that are now no longer available

isbn
urn-nbn

Altmetric score

isbn
urn-nbn
Total: 5030 hits
CiteExportLink to record
Permanent link

Direct link
Cite
Citation style
  • apa
  • ieee
  • modern-language-association-8th-edition
  • vancouver
  • Other style
More styles
Language
  • de-DE
  • en-GB
  • en-US
  • fi-FI
  • nn-NO
  • nn-NB
  • sv-SE
  • Other locale
More languages
Output format
  • html
  • text
  • asciidoc
  • rtf