Research output

BEPS Hybrid Entities Proposal: A slippery slope, especially for developing countries

Research output: Contribution to journalArticleScientificpeer-review

Associated researcher

Associated organisations

Abstract

Article 1(2) has been proposed in the final report on G20/OECD's Base Erosion and Profit Shifting (BEPS) Action 2. Two principle purposes of the BEPS project can be identified: First, to combat against aggressive tax planning which results in less than single taxation, and secondly, to allocate taxing rights to the state in which the economic activity gives rise to income. This article demonstrates that Article 1(2) tends to enable diametrically opposite results.

    Research areas

  • BEPS, Hybrid Entities, tax treaties, tax avoidance, aggressive tax planning, OECD, G20
View graph of relations

Details

Original languageEnglish
Pages (from-to)357-362
JournalTax Notes International
Volume85
Issue number4
StatePublished - 23 Jan 2017