Search results with tag "Hybrid mismatch"
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.
(Treaty Issues) - oecd.org
www.oecd.orgHybrid mismatch arrangements can be used to achieve unintended double nontaxation or long- term tax deferral by, for instance, creating - two deductions for one borrowing, generating deductions without corresponding income inclusions,
OCTOBER 2015• BEPS UPDATE No. 3 www.oecd.org …
www.oecd.orgwww.oecd.org/policy-briefs OECD Policy Brief OCTOBER 2015 •BEPS UPDATE No. 3 measures takes into account what happens beyond borders. Model rules are available to eliminate Hybrid Mismatch