Hybrid mismatch arrangements
Found 3 free book(s)OECD/G20 Base Erosion and Profit Shifting Project OECD/G20 ...
www.oecd.orgother areas, such as recommendations on hybrid mismatch arrangements and best practices on interest deductibility, countries have agreed a general tax policy direction. In these areas, they areexpected to converge over time through the implementation of the agreed common approaches, thus enabling further consideration of whether such
Multilateral Convention to Implement Tax Treaty-Related ...
www.oecd.orghybrid mismatch arrangements, prevent treaty abuse, address artificial avoidance of permanent establishment status, and improve dispute resolution; Conscious of the need to ensure swift, coordinated and consistent implementation of the treaty- -
Part 38-02-01E - Form CT1 2020 - Revenue
www.revenue.iereferred to as anti-hybrid rules. The purpose of anti-hybrid rules is to prevent arrangements that exploit differences in the tax treatment of a financial instrument or an entity, under the tax laws of two or more jurisdictions, to generate a tax advantage. The tax advantage arising from this is referred to as a hybrid mismatch outcome.