Avräkningsmetoden : En skatterättslig studie om undvikande av internationell dubbelbeskattning

Detta är en avhandling från Uppsala : Iustus förlag

Sammanfattning: The territorial scope of modern income tax systems frequently leads to the occurrence of international double taxation, i.e., that the same income is taxed in two or more states. In cases of international double taxation, a foreign tax credit may be given by applying either the method article in Swedish tax treaties or the unilateral Foreign Tax Credit Act. The foreign tax credit method seeks to eliminate double taxation or, in other words, to achieve single taxation. In principle, the taxpayer’s residence state has the responsibility to credit foreign taxes which have been imposed because the income source is located abroad.The overall aim of this thesis is to study the Swedish foreign tax credit method in order to arrive at an understanding of the method as a whole. To achieve this aim, a question is posed, namely ”which concept of double taxation characterizes the foreign tax credit method?” The thesis is divided into three parts. The first part contains a reading of the historical and conceptual background of the phenomenon of international double taxation and the foreign tax credit method. It also consists of a study of the general systematic and territorial aspects of the foreign tax credit method. The second part deals with how to identify such international double taxation which the foreign tax credit method is aimed at eliminating. The third part concerns how the foreign tax credit method seeks to achieve single taxation in a situation where international double taxation has been identified. The last two parts corresponds to the two essential elements of the foreign tax credit method.When interpreting the foreign tax credit method, the concept of double taxation is related to fundamental concepts of modern income tax law, such as tax subject, tax object, and income tax. The classical concept of international double taxation has some relevance for the Swedish foreign tax credit method, although distinctive features of the Swedish tax system require special considerations. Regarding the second essential element of the foreign tax credit method, the achievement of single taxation, an important aspect is also to consider how different ways of eliminating double taxation affect the relationship between the residence state and the source state.

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