Franklin

Neutralising the Effects of Hybrid Mismatch Arrangements / Organisation for Economic Co-operation and Development.

Author/Creator:
Organisation for Economic Co-operation and Development.
Publication:
Paris : OECD Publishing, 2014.
Series:
OECD/G20 Base Erosion and Profit Shifting Project 23132612.
OECD/G20 Base Erosion and Profit Shifting Project 23132612.
Format/Description:
Government document
Book
1 online resource (100 pages)
Subjects:
Taxation.
Summary:
This report sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements. Once translated into domestic law, the recommendations in Part 1 of the report will neutralise the effect of cross-border hybrid mismatch arrangements that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part 1 of the report will be supplemented by a commentary, which will explain the recommended rules and illustrate their application with practical examples. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.
Notes:
Title from title screen (viewed May 1, 2017).
Contributor:
SourceOECD (Online Service)
ISBN:
9789264218819
Access Restriction:
Restricted for use by site license.
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