Neutralising the Effects of Hybrid Mismatch Arrangements [electronic resource] / Organisation for Ec...
Neutralising the Effects of Hybrid Mismatch Arrangements [electronic resource] / Organisation for Ec...
Neutralising the Effects of Hybrid Mismatch Arrangements [electronic resource] / Organisation for Economic Co-operation and Development
About this item
Full title
Author / Creator
Publisher
Paris : OECD Publishing, 2014.
Alternative title
Date
2014.
Record Identifier
MMS ID
Language
English
Formats
Physical Description
Physical content
1 online resource (103 p.)
Content type
text
Media type
computer
Carrier type
online resource
Contents
Foreword; Table of contents; Abbreviations and acronyms; Executive summary; Summary of Part I; Summary of Part II; Introduction; Previous work undertaken by the OECD on hybrid mismatch arrangements; BEPS Action Plan; Part I - Recommendations for the design of domestic rules; Chapter 1.Definition of...
Chapter 2.Arrangements that produce D/NI outcomesRecommended hybrid mismatch rule for financial instruments; Other recommendations for the tax treatment of financial instruments; Recommended hybrid mismatch rule for disregarded payments made by a hybrid payer; Recommended hybrid mismatch rule for re...
Chapter 4.Arrangements that produce indirect D/NI outcomesRecommended rule for indirect D/NI outcomes; Chapter 5.Implementation; Recommendations on implementation and co-ordination; Chapter 6.Definitions in relation to scope; Definition of structured arrangement; Definition of related person, contro...
Rule providing for the denial of deductionsDefensive rule requiring the inclusion of a payment in ordinary income; Exemption method; Credit method; Potential application of anti-discrimination provisions in the OECD Model Convention
Publication information
Publisher
Paris : OECD Publishing, 2014.
Date Published
2014.
Subjects
More information
Scope and Contents
Summary
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 th...
Alternative Titles
Full title
Neutralising the Effects of Hybrid Mismatch Arrangements [electronic resource] / Organisation for Economic Co-operation and Development
Variant title
BOOK
Authors, Artists and Contributors
Author / Creator
Notes
General note
OECD/G20 Base Erosion and Profit Shifting Project, 23132612.
Description based upon print version of record.
Language note
English
Identifiers
Primary Identifiers
Record Identifier
74VK3lxEWBVO
Permalink
https://devfeature-collection.sl.nsw.gov.au/record/74VK3lxEWBVO
Other Identifiers
ISBN
92-64-21881-5
DDC
343.067
MMS ID
991023945871802626
