Примери за използване на Artificial arrangement на Английски и техните преводи на Български
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(ca) whether the cross-border conversion constitutes an artificial arrangement.
From creating purely artificial arrangements for taxation purposes only;
(ca) whether the cross-border conversion constitutes an artificial arrangement.
Any artificial arrangement carried out for tax avoidance purposes would be ignored and companies would be taxed instead on the basis of actual economic substance”.
However, this in-depth assessment should not be carried out systematically but rather on a case-by-case basis,where there are serious concerns as to the existence of an artificial arrangement.
They should also adopt acommon General Anti-Abuse Rule, under which they could ignore any artificial arrangement carried out for tax avoidance purposes and tax instead on the basis of actual economic substance.
(b) a description of all factual elements necessary for the competent authorities, designated,to carry out an in-depth assessment to determine whether the intended cross-border merger constitutes an artificial arrangement, including as a minimum the following.
Abusive conversions, mergers ordivisions constituting artificial arrangements or social dumping, but also reducing fiscal obligations or undercutting social rights of employees should therefore be avoided in order to respect Treaty principles and values.
(b) a description of all factual elements necessary to carry out an in-depth assessment to determine whether the intended cross-border merger constitutes an artificial arrangement, including as a minimum the following.
Member States shall ensure, in order to assess whether the cross-border merger constitutes an artificial arrangement, that the competent authorities carry out an in-depth assessment of all relevant facts and circumstances and that they take into account at a minimum the following.
Today's proposal puts in place clear procedures for companies, with strong safeguards to protect employees' rights and, for the first time,to prevent artificial arrangements aiming at tax avoidance and other abuses".
Member States shall ensure in order to assess whether the cross-border conversion constitutes an artificial arrangement, that the competent authority of the departure Member State carries out an in-depth assessment of all relevant facts and circumstances and shall take into account at a minimum the following.
(f) a description of all factual elements necessary,to carry out an in-depth assessment to determine whether the intended cross-border division constitutes an artificial arrangement in accordance with Article 160p, including at a minimum the following.
This should cover investments within the Union by means of artificial arrangements that do not reflect economic reality and circumvent the screening mechanisms and screening decisions, where the investor is ultimately owned or controlled by a natural person or an undertaking of a third country.
Member States shall ensure that the competent authority of the departure Member State shall not authorise the cross- border conversion where it determines, after an examination of the specific case and having regard to all relevant facts and circumstances,that it constitutes an artificial arrangement.
Such measures shall cover investments from the Union made through"artificial arrangements" that do not reflect the economic realities and circumvent the screening mechanisms and screening decisions, where the investor is ultimately owned or controlled by a natural person or an undertaking of a third country.
It is therefore necessary to consider whether the charging of withholding tax on dividends paid to States party to the EEA Agreement(and the associated restriction on the free movement of capital) is justified in order to prevent tax evasion even thoughit does not specifically address artificial arrangements.(36).
The competent authorities of the Member State of departure will not authorize the cross-border conversion if, following the review,they determine that the operation represents an artificial arrangement aimed at obtaining undue tax advantages or at unduly prejudicing the legal or contractual rights of employees, creditors or minority members.
Member States shall ensure that the competent authority of the departure Member State does not issue a pre-conversion certificate for the cross-border conversion where it determines, after carrying out an in-depth assessment of the specific case and having regard to all relevant facts and circumstances,that it constitutes an artificial arrangement.
(45)In order to ensure the accuracy of the information contained in the draft terms of division and in the reports addressed to the members and employees andto provide factual elements necessary to assess whether the proposed division constitutes an artificial arrangement which could not be authorised, an independent expert report to assess the division plan should be required to be prepared.
The competent authority should decide whether to issue a pre-division certificate within two months of the reception of all the necessary documents and information,unless it has serious concerns as to the existence of an artificial arrangement or that the division does not involve the actual pursuit of genuine economic activity.
At the same time, in the absence of a level playing field in the form of coherent social and fiscal rules, these developments went hand-in-hand with the proliferation of letterbox companies and abusive practices,constituting artificial arrangements and circumventing fiscal and social security obligations as well as undercutting workers' rights.
The competent authority of the departure Member State should decide on the issue of the pre-conversion certificate within two months of the reception of all the necessary documents andinformation unless it has serious concerns as to the existence of an artificial arrangement or that the conversion does not involve the actual pursuit of genuine economic activity.
Each competent authority of the Member State of the merging companies should decide on the issue of the pre-merger certificate within two months of the reception of all the necessary documents andinformation unless it has serious concerns as to the existence of an artificial arrangement or that the merger does not involve actual pursuit of genuine economic activity.
(35a) In order to assess the accuracy of the information contained in the draft terms of merger and in the reports addressed to the members and employees andto provide factual elements necessary to assess whether the proposed merger constitutes an artificial arrangement, an independent expert report should be required to be prepared in order to assess the proposed cross-border merger.
(45) The competent national authorities should be able to assess the accuracy of the information contained in the draft terms of division and in the report addressed to the members and employees andto provide factual elements necessary to assess whether the proposed division constitutes an artificial arrangement which could not be authorised, an independent expert report to assess the division plan should be required to be prepared.