Neutralising The Effects Of Hybrid Mismatch Arrangements

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Neutralising The Effects Of Hybrid Mismatch Arrangements

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Author : Oecd
language : en
Publisher: OCDE
Release Date : 2014-09-16

Neutralising The Effects Of Hybrid Mismatch Arrangements written by Oecd and has been published by OCDE this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-09-16 with Business & Economics categories.

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.

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.

Neutralising The Effects Of Hybrid Mismatch Arrangements Chinese Version

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Author : OECD
language : zh-CN
Publisher: OECD Publishing
Release Date : 2015-06-29

Neutralising The Effects Of Hybrid Mismatch Arrangements Chinese Version 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 2015-06-29 with categories.

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.

Neutralising The Effects Of Branch Mismatch Arrangements Action 2

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Author : Organization for Economic Development and Cooperation
language : en
Publisher: Organization for Economic Co-Operation & Development
Release Date : 2017

Neutralising The Effects Of Branch Mismatch Arrangements Action 2 written by Organization for Economic Development and Cooperation and has been published by Organization for Economic Co-Operation & Development this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with Corporations categories.

This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report). Branch mismatches arise where the ordinary rules for allocating income and expenditure between the branch and head office result in a portion of the net income of the taxpayer escaping the charge to taxation in both the branch and residence jurisdiction. Unlike hybrid mismatches, which result from conflicts in the legal treatment of entities or instruments, branch mismatches are the result of differences in the way the branch and head office account for a payment made by or to the branch. The 2017 report identifies five basic types of branch mismatch arrangements that give rise to one of three types of mismatches: deduction / no inclusion (D/NI) outcomes, double deduction (DD) outcomes, and indirect deduction / no inclusion (indirect D/NI) outcomes. This report includes specific recommendations for improvements to domestic law intended to reduce the frequency of branch mismatches as well as targeted branch mismatch rules which adjust the tax consequences in either the residence or branch jurisdiction in order to neutralise the hybrid mismatch without disturbing any of the other tax, commercial or regulatory outcomes. The annexes of the report summarise the recommendations and set out a number of examples illustrating the intended operation of the recommended rules.

Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Branch Mismatch Arrangements Action 2 Inclusive Framework On Beps

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-07-27

Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Branch Mismatch Arrangements Action 2 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 2017-07-27 with categories.

This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).

Neutralising The Effects Of Hybrid Mismatch Arrangements Korean Version

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Author : OECD
language : ko
Publisher: OECD Publishing
Release Date : 2015-06-12

Neutralising The Effects Of Hybrid Mismatch Arrangements Korean Version 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 2015-06-12 with categories.

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”.

Model Tax Convention On Income And On Capital Condensed Version 2017

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-12-18

Model Tax Convention On Income And On Capital Condensed Version 2017 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 2017-12-18 with categories.

This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...

Action Plan On Base Erosion And Profit Shifting

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2013-07-19

Action Plan On Base Erosion And Profit Shifting 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 2013-07-19 with categories.

This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.