Advance pricing arrangement (“APA”) becomes a common tool to attract foreign investors to carry out their business in the Member States’ territory. The advantage of APA which providing legitimate expectations to the taxpayers is one of the reasons of why the companies file an APA request to the tax authorities. However, APAs are not free from issues or problems arose, especially in relation to t

Milleniemål två och delvis tre har haft som ändamål att alla barn ska få gå i skolan och att skolan ska vara en jämställd plats år 2015. Dessa mål är fortfarande inte uppnådda och framför allt flickor drabbas av detta utfall. Syftet med denna uppsats är således att utvärdera UNESCOs egen tolkning av resultaten av deras projekt Education For All. Detta kommer att uppnås genom en granskning av rappo

This paper aims to explore the role of the Syrian civil society in the ongoing conflict from the concept of transitional justice. Broadening the civil society understanding provides a tool to approach the overlooked social capital in the Syrian society. Exploring the approach from non-profit groups to victims, I aim to understand a possible approach to transitional justice in Syria. I argue for th

The purpose of this work is to investigate the negative legal force of decisions under immigration law compared to under administrative law in general, with the exception of environmental protection law, public purchasing law and certain local government laws. The comparison refers to the underlying ideas, presence, factual extent and protection of the factual extent. Negative legal force of the

Syftet med uppsatsen är att utforska och behandla statschefers rätt till immunitet vid grova folkrättsbrott. Den centrala frågan för uppsatsen är om statschefer idag kan begå brott mot folkrätten och ändå beviljas straffrihet. Immunitet för statschefer har utvecklats ur immuniteten för stater, som är baserad på att varje stat är suverän och likställd med andra stater. Fram till mitten av nittonhuThe aim of this thesis is to explore the status of the immunity afforded to heads of state for serious international crimes. The central question asked is whether heads of state at the present time can commit international crimes and still be granted impunity. The concept of head of state immunity developed from immunity afforded to states and is based on the principles of state-sovereignty and e

After the Arab spring, states in the MENA-region that were enrolled in the popular uprisings are now entering different settings. Some have been more successful, and reaching all the way to democratic consolidation. Others like Egypt are currently experiencing severe backlashes. In this post revolution context, time is starting to run out for an escape out of the transitional maze. Tunisia is not

With nature as its main attraction, ecotourism is promoted as a savior for both development and conservation. However, neoliberal logics of turning biodiversity into commodities have resulted in an increasing amount of ecotourism operators offering interactive experiences with charismatic wildlife. Although the animals are captive and forcefully employed as labor, the encounters are claimed to sup

In a globalized world where power-relations are changing, the need to reformulate the framework of global trade and trade-liberalization to be more conducive for development has been increasingly recognized in trade and development forums. This has resulted in increased donor focus on trade related development assistance and the moral justifications of trade-relations. This thesis set out to quest

Since the creation of the Palestinian National Authority (PNA), donor involvement in Palestine has perversely influenced both an institution-building process and a de-mobilization and de-politicization of the Palestinian population. Some even say donors have effected a neoliberal reformation of society. This thesis intends to problematize the influence donors occupy over the incipient national ide

The main focus of this paper is to shed light on an area of research that is relatively new in the Swedish context. A part of the purpose of this study is based on wanting to understand and study why the Swedish veterans who are in need of help and support after coming back home from doing service abroad is not given the appropriate form of help, or alternatively, seeking out the help that is avai

The purpose of this work is to propose an interpretation of the law as it stands today in order to provide a coherent and cohesive legal framework regarding the treatment of expenses connected with the sale of shares. In order to achieve such purpose, this work includes an extensive analysis of the case-law of the European Court of Justice regarding this subject matter and a critical study of the

Diamonds are one of the most valuable elements on earth, having the potential to contribute to economic development. However, in recent years, it has come to the world’s attention that the illicit trading in diamonds has financed gruesome wars and human rights abuse, and the problem has not gone away. These diamonds have come to be termed as conflict diamonds. In order to mitigate conflict diamond

This thesis considers the extent to which Member States may be authorized under Community law to restrict the reach of their charitable tax incentives. The limits that can be imposed by Member States in setting objectives for charitable tax incentives that are tied to nationality or domestic territory have not been clarified. Finally, this thesis assesses whether the tax incentives provided for ch

The current OECD´s PE threshold requires either a direct physical presence (fixed place of business) or an indirect presence through a legal representative (dependent agent). On the other hand, Model Conventions such as the UN MC, provide a wider PE threshold, including income generating activities which are not included under the OECD PE threshold. Nevertheless, it should be noted that the UN MC

The number of self-service libraries (”meröppna bibliotek”) is increasing in Sweden, yet there is not much research in the field. The starting point of this master’s thesis is this void. The concept of self-service library means that during some of the opening hours the library is unstaffed, but users can enter and use the library services. I understand libraries as part of a complex context in wh

The world has entered the Second Nuclear Age. New structures and dynamics are argued to be present within the context of nuclear weapons. The states India, Pakistan and China are three cases where the nuclear stockpiles are increasing and becoming more technological advanced. The hypothesis of this paper is that the increase of nuclear stockpiles in the cases is due to a dynamic characteristic of

Under a long time in the European Union, the topic of taxation of vouchers have been highly discussed. Because of the lack of harmonized rules, the Member States have individually created both definitions of different types of vouchers, and rules on how to tax the different vouchers. However, the fact that the Member States use domestic rules is not a problem when the vouchers are used domesticall

Civic engagement plays an important role in governmental transparency – so how does transparency work in a non-democracy like China where the political and juridical systems repress public participation? Through quantitative methods this paper examines how a selection of citizens in Shanghai, China, make use of environmental information made available through the Chinese government’s Open Environm

Denna uppsats utgör undertecknads examensarbete vid juristprogrammet på Lunds universitet. Syftet med uppsatsen har varit att utreda vad sekundosuccessorerna har för rätt och skydd genom den svenska lagstiftningen. Ur ett arvshistoriskt perspektiv har efterlevande make haft väldigt svaga rättigheter. Efterlevande makes och bröstarvingarnas intressen stod mot varandra. I början på 1900- talet ansThis essay represents the undersigned's master thesis at the Mastar of Law program at Lund University. The aim of the thesis is to investigate what legal rights and protection a secondary successor has under Swedish law. From an inheritance historical perspective, the surviving spouse had very weak legal rights. Surviving spouses and direct heirs had opposing interests. In the early 1900s th

Organisational learning is assumed to be a part of creating improved work processes in an organisation. This type of learning can be difficult to achieve in operational and reactive work environments. Challenges in observable causality, time constraints and complex external conditions means that the operational control room is one of those reactive work environments. There is a need for a system t