Volume 44 (2016) / Issue 8/9

Marlous Verhoog, Almut Breuer, 'Hybrid Entity Issues in a Tax Treaty Context: OECD Approach versus Actual Tax Treaties' (2016) 44 Intertax, Issue 8/9, pp. 684–700

Abstract

In this article the authors describe the issues relating to hybrid entities in a tax treaty context and the solution to these issues as proposed by the Organization for Economic Co-operation and Development (OECD) in the context of Base Erosion and Profit Shifting Action 2. The OECD solution and possible improvements thereto are analysed in light of the international tax treaty practice of the Netherlands and Germany.

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ISSN: 0165-2826
ID: TAXI2016057