Addressing hybrid mismatch arrangements - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Addressing hybrid mismatch arrangements write by Policy and Stratgey, Inland Revenue, New Zealand. This book was released on 2016-09-06. Addressing hybrid mismatch arrangements available in PDF, EPUB and Kindle. Hybrid mistmatch arrangements are one of the main base erosion and profit shifting (BEPS) strategies used by some large international companies to pay little or no tax anywhere in the world. The OECD developed recommendations for anti-hybrid measures in its 15 point Base Erosion and Profit Shifting (BEPS) Action Plan. This Government discussion document seeks comments on how the OECD recommendations could be implemented in New Zealand. Part I of the document describes the problem of hybrid mismatch arrangements, the case for responding to the problem, and a summary of the OECD recommendations. Part II of the document explains the OECD recommendations in greater depth and discusses how they could be incorporated into New Zealand law.
Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report
Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report write by OCDE,. This book was released on 2015-10-15. Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report available in PDF, EPUB and Kindle. 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 that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part I of the report sets out recommendations for rules to address hybrid mismatches in respect of payments made under a hybrid financial instrument or payments made to or by a hybrid entity. It also recommends rules to address indirect mismatches that arise when the effects of a hybrid mismatch arrangement are imported into a third jurisdiction. The recommendations are supported by a commentary and examples to illustrate how they should apply. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.
Neutralising the Effects of Hybrid Mismatch Arrangements
Neutralising the Effects of Hybrid Mismatch Arrangements - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Neutralising the Effects of Hybrid Mismatch Arrangements write by Oecd. This book was released on 2014-09-16. Neutralising the Effects of Hybrid Mismatch Arrangements available in PDF, EPUB and Kindle. 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 that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part 1 of the report will be supplemented by a commentary, which will explain the recommended rules and illustrate their application with practical examples. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.
Hybrid Mismatch Arrangements : Interest Deductions and Other Financial Payments
Hybrid Mismatch Arrangements : Interest Deductions and Other Financial Payments - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Hybrid Mismatch Arrangements : Interest Deductions and Other Financial Payments write by H. Buesching. This book was released on 2016. Hybrid Mismatch Arrangements : Interest Deductions and Other Financial Payments available in PDF, EPUB and Kindle. The OECD base erosion and profit shifting (BEPS) 15-point Action Plan contains two action points addressing aspects of financing in the broadest sense. Action 2 is intended to neutralize the effects of hybrid mismatch arrangements, and Action 4 seeks to limit base erosion involving interest deductions and other financial payments. These action points essentially concern issues regarding the allocation of taxation associated with internal group financing arrangements. However, they also address structured financing. This article examines both action points.
OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report
OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report write by OECD. This book was released on 2015-10-05. OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report available in PDF, EPUB and Kindle. Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.
