Addressing Hybrid Mismatch Arrangements
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Addressing Hybrid Mismatch Arrangements
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Author : Policy and Stratgey, Inland Revenue, New Zealand
language : en
Publisher: Policy and Strategy, Inland Revenue, New Zealand
Release Date : 2016-09-06
Addressing Hybrid Mismatch Arrangements written by Policy and Stratgey, Inland Revenue, New Zealand and has been published by Policy and Strategy, Inland Revenue, New Zealand this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-09-06 with categories.
Hybrid mistmatch arrangements are one of the main base erosion and profit shifting (BEPS) strategies used by some large international companies to pay little or no tax anywhere in the world. The OECD developed recommendations for anti-hybrid measures in its 15 point Base Erosion and Profit Shifting (BEPS) Action Plan. This Government discussion document seeks comments on how the OECD recommendations could be implemented in New Zealand. Part I of the document describes the problem of hybrid mismatch arrangements, the case for responding to the problem, and a summary of the OECD recommendations. Part II of the document explains the OECD recommendations in greater depth and discusses how they could be incorporated into New Zealand law.
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements Action 2 2015 Final Report
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2015-10-05
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements Action 2 2015 Final Report written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-10-05 with categories.
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2014-09-16
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-09-16 with categories.
This report, produced by the OECD/G20 Project on Base Erosion and Profit Shifting 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.
Limiting Base Erosion
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Author : Erik Pinetz
language : en
Publisher: Linde Verlag GmbH
Release Date : 2017-08-30
Limiting Base Erosion written by Erik Pinetz and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-08-30 with Law categories.
Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to properly implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis in the literature of all the issues related to base erosion proves to be of the utmost importance in order to provide practical guidance to the Member countries during that the process of implementation. This book deals especially with four key areas of interest:Limiting base erosion by neutralizing the effects of hybrid mismatch arrangementsLimiting base erosion by strengthening CFC rulesMeasures against base erosion via interest deductions and other financial paymentsLimiting base erosion by improving transfer pricing rules.On that basis, 27 concrete topics were chosen in order to address the four key areas of interest from different viewpoints. Base erosion and the challenges they present: read more in “Limiting Base Erosion”.
Oecd G20 Base Erosion And Profit Shifting Project Developing A Multilateral Instrument To Modify Bilateral Tax Treaties
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2014-09-16
Oecd G20 Base Erosion And Profit Shifting Project Developing A Multilateral Instrument To Modify Bilateral Tax Treaties written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-09-16 with categories.
Produced by the OECD/G20 Base Erosion and Profit Shifting Project, this report identifies the issues arising from the development of a multilateral instrument that modifies bilateral tax treaties.
Oecd G20 Base Erosion And Profit Shifting Project Limiting Base Erosion Involving Interest Deductions And Other Financial Payments Action 4 2016 Update Inclusive Framework On Beps
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2016-12-22
Oecd G20 Base Erosion And Profit Shifting Project Limiting Base Erosion Involving Interest Deductions And Other Financial Payments Action 4 2016 Update Inclusive Framework On Beps written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-12-22 with categories.
The 2015 Report on BEPS Action 4 established a common approach which directly links an entity’s net interest deductions to its level of economic activity, based on taxable EBITDA. Further work on two aspects of the common approach was completed in 2016 and this is included in this update.
Oecd G20 Base Erosion And Profit Shifting Project Limiting Base Erosion Involving Interest Deductions And Other Financial Payments Action 4 2015 Final Report
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2015-10-05
Oecd G20 Base Erosion And Profit Shifting Project Limiting Base Erosion Involving Interest Deductions And Other Financial Payments Action 4 2015 Final Report written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-10-05 with categories.
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 4.
Hybrid Entities In Tax Treaty Law
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Author : Sriram Govind
language : en
Publisher: Linde Verlag GmbH
Release Date : 2020-09-03
Hybrid Entities In Tax Treaty Law written by Sriram Govind and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-09-03 with Law categories.
Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.
Oecd G20 Base Erosion And Profit Shifting Project Addressing The Tax Challenges Of The Digital Economy Action 1 2015 Final Report
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2015-10-05
Oecd G20 Base Erosion And Profit Shifting Project Addressing The Tax Challenges Of The Digital Economy Action 1 2015 Final Report written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-10-05 with categories.
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 1.
Non Discrimination In Tax Treaty Law And World Trade Law
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Author : Kasper Dziurdź
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-07-23
Non Discrimination In Tax Treaty Law And World Trade Law written by Kasper Dziurdź and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-07-23 with Law categories.
Non-discrimination is a central obligation under both tax treaty and trade law. However, in seeking to strike a balance between national and international interests, its application differs in the two areas of practice. This deeply researched and authoritative work, which explains the policy issues and how non-discrimination analysis works, provides a comprehensive review of non-discrimination rules in WTO and tax treaty law, combining a critical commentary on case law with proposals for an innovative concept for solving cases of discrimination in tax treaty law. Among the practical issues affecting non-discrimination examined in detail are the following: implications that can be drawn from the concepts of non-discrimination under WTO law and Article 24 of the OECD Model; direct and indirect discrimination and analysis of comparability in WTO law and tax treaty law; the MFN and NT rules under the GATT and GATS; the meaning of ‘likeness’ and ‘less favourable treatment’; claiming non-discriminatory tax treatment before tax administrations and courts under a tax treaty; justification of measures against harmful tax competition, low taxation and hybrid mismatch arrangements; thin capitalisation rules, progressive tax rates, foreign losses, group taxation and relief from juridical and economic double taxation under Article 24 of the OECD Model; and integrating a justification defence into any stage of a non-discrimination analysis. The author establishes to what extent formal, substantive and subjective approaches may be applied in a non-discrimination analysis, providing the reasons for the approaches taken. A two-step comparability procedure is applied to selected cases of potential tax discrimination, demonstrating how policy arguments can be addressed under Article 24 of the OECD Model. Drawing on over a half-century of case law in both areas of practice, this comprehensive study of the non-discrimination rules under WTO law and international tax law will be invaluable in systematically solving cases of tax discrimination under Article 24 of the OECD Model and putting forward arguments at any stage of a WTO analysis. Policymakers will benefit from the author’s clear explanation of how national law should comply with international obligations. Also, taxpayers’ advisers will proceed confidently in claims of tax treaty discrimination, and academics will discover an incomparable overview and analysis of anti-discrimination rules in international trade law and double taxation conventions.