Neutralising the Effects of Hybrid Mismatch Arrangements
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 effe...
| Corporate Author: | |
|---|---|
| Format: | eBook |
| Language: | English |
| Published: |
Paris
OECD Publishing
2014
|
| Series: | OECD/G20 Base Erosion and Profit Shifting Project
|
| Subjects: | |
| Online Access: | |
| Collection: | OECD Books and Papers - Collection details see MPG.ReNa |
| 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 |
|---|---|
| Physical Description: | 100 p. 16 x 23cm |
| ISBN: | 9789264218819 |