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This book is now Out of Print.
A new edition has been published, the details can be seen here:
Double Non-taxation and the Use of Hybrid Entities 2nd ed isbn 9789403546667

Double Non-taxation and the Use of Hybrid Entities: An Alternative Approach in the New Era of BEPS


ISBN13: 9789041199911
New Edition ISBN: 9789403546667
Published: May 2018
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: Out of print



Double Non-taxation and the Use of Hybrid Entities provides a critical review of the Economic Co-operation and Development’s (OECD’s) approach in Base Erosion and Profit Shifting (BEPS) – Action 2 and proposes a deeply informed alternate method based on the tax policy aims of simplicity, coherence and ease of administration. The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations within the tax world seem to be leading to an international commitment most materially manifested in the OECD BEPS project. This book provides a consistent option to address the issues of hybrid entity mismatches, which may be used as a point of comparison with regard to the current OECD BEPS proposals and as a viable alternative for tax policymakers.

What’s in this book:

The author analyzes the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasizing the international tax context, including the application of tax treaties. Among the seminal matters covered are the following:

  • foundations of the concepts of double non-taxation and hybrid entities, absent of the specific limitations of domestic tax legislation;
  • extensive analysis based on the rules of characterization of foreign entities for tax purposes in the United States, Spain, Denmark and Germany, as well as on some examples of solutions taken from the tax treaties of Poland/United States and Canada/United States;
  • detailed analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument, especially having in mind the position of developing (source) countries; and
  • European Union (EU) tax law as part of the international context, including an extensive analysis on the EU Anti-Tax Avoidance Directives, ATAD I and ATAD II.
How this will help you:

This book will prove to be of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international and EU tax law merely for its unparalleled clarification of the issues. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding double non-taxation and hybrid entities, this book elaborates on solutions applicable to a generality of cases worldwide, clarifies that a more fundamental solution with regard to hybrid entities brings more consistent tax treaty outcomes, and hugely promotes the urgent quest for alternative solutions.

Subjects:
Taxation
Contents:
Preface
List of Abbreviations
List of Figures
Acknowledgments
Introduction
PART I
Double Non-taxation: Delimiting the Boundaries of a Stigmatized Concept
CHAPTER 1
Double Non-taxation: A Conceptual Analysis
CHAPTER 2
Double Non-taxation and Bilateral Tax Treaties
PART II
Hybrid Entities: A Domestic Decision with International Consequences
CHAPTER 3
The Hybrid Entities’ Conundrum: A (Simple) Tax Characterization Issue
CHAPTER 4
Hybrid Entities and the Entitlement to Tax Treaty Benefits
PART III
Double Non-Taxation and Hybrid Entities: The New Trend of (Mis) Matching Outcomes
CHAPTER 5
Hybrid Mismatch Arrangements and Linking Rules: Creating Artificial (Mis)Matches
CHAPTER 6
Hybrid Entities Without Double Non-taxation: An Alternative Approach
CHAPTER 7
Summary and Conclusions
List of References
Index

Series: Series on International Taxation

The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model ISBN 9789403542973
To be published May 2024
Kluwer Law International
£92.00
The Resolution of International Tax Disputes ISBN 9789403520889
To be published May 2024
Kluwer Law International
£75.00
Taxation of Derivatives and Cryptoassets 2nd ed ISBN 9789403523835
To be published April 2024
Kluwer Law International
£143.00
Double Non-taxation and the Use of Hybrid Entities 2nd ed ISBN 9789403546667
Published December 2023
Kluwer Law International
£144.00
Double Non-taxation and the Use of Hybrid Entities 2nd ed (eBook) ISBN 9789403546766
Published December 2023
Kluwer Law International
£144.00
(ePub)
Buy
Tax Treaty Dispute Resolution: Lessons from the Law of the Sea (eBook) ISBN 9789403534176
Published November 2023
Kluwer Law International
£81.00
(ePub)
Buy
Tax Treaty Dispute Resolution: Lessons from the Law of the Sea ISBN 9789403534077
Published November 2023
Kluwer Law International
£81.00
The Role of Tax Law in Mergers and Acquisitions: A Chinese Perspective (eBook) ISBN 9789403537627
Published August 2022
Kluwer Law International
£96.00
(ePub)
Buy
The Role of Tax Law in Mergers and Acquisitions: A Chinese Perspective ISBN 9789403537412
Published August 2022
Kluwer Law International
£96.00
£139.00
(ePub)
Buy
£139.00
Coordination and Cooperation: Tax Policy in the 21st Century ISBN 9789403537405
Published December 2021
Kluwer Law International
£128.00
Coordination and Cooperation: Tax Policy in the 21st Century (eBook) ISBN 9789403537603
Published December 2021
Kluwer Law International
£128.00
(ePub)
Buy
Exploring the Nexus Doctrine In International Tax Law (eBook) ISBN 9789403533643
Published May 2021
Kluwer Law International
£75.00
(ePub)
Buy
Regulation and Tax in Space (eBook) ISBN 9789403533940
Published May 2021
Kluwer Law International
£79.00
(ePub)
Buy
Exploring the Nexus Doctrine In International Tax Law ISBN 9789403533636
Published May 2021
Kluwer Law International
£75.00
Regulation and Tax in Space ISBN 9789403533933
Published May 2021
Kluwer Law International
£79.00
Permanent Establishment: Erosion of a Tax Treaty Principle 2nd ed ISBN 9789403520612
Published July 2020
Kluwer Law International
£375.00
Permanent Establishment: Erosion of a Tax Treaty Principle 2nd ed (eBook) ISBN 9789403520643
Published July 2020
Kluwer Law International
£375.00
(ePub)
Buy
International Taxation of Banking ISBN 9789403510941
Published February 2020
Kluwer Law International
£168.00
International Taxation of Banking (eBook) ISBN 9789403510958
Published February 2020
Kluwer Law International
£168.00
(ePub)
Buy
Tax Treaty Residence of Entities ISBN 9789403513010
Published November 2019
Kluwer Law International
£108.00
Hybrid Financial Instruments, Double Non-Taxation and Linking Rules ISBN 9789403510743
Published August 2019
Kluwer Law International
£130.00
Tax and the Digital Economy: Challenges and Proposals for Reform ISBN 9789403503615
Published May 2019
Kluwer Law International
£111.00
Taxation, Virtual Currency and Blockchain ISBN 9789403501031
Published December 2018
Kluwer Law International
£96.00
International Taxation of Energy Production and Distribution ISBN 9789041191014
Published May 2018
Kluwer Law International
£159.00
£110.00
£110.00
Winning the Tax Wars: Tax Competition and Cooperation ISBN 9789041194602
Published December 2017
Kluwer Law International
£119.00
BRICS and International Tax Law ISBN 9789041194350
Published December 2017
Kluwer Law International
£149.00
Legal Interpretation of Tax Law 2nd ed ISBN 9789041184733
Published October 2017
Kluwer Law International
£149.00
Other Income under Tax Treaties ISBN 9789041166104
Published September 2015
Kluwer Law International
£241.00
General Anti - avoidance Rules for Major Developing Countries ISBN 9789041158390
Published October 2014
Kluwer Law International
£154.00
Proportionality and Fair Taxation ISBN 9789041158383
Published October 2014
Kluwer Law International
£167.00
Legal Interpretation of Tax Law ISBN 9789041149459
Published September 2014
Kluwer Law International
Out of print
Tax Reform in the 21st Century: A Volume in Memory of Richard Musgrave ISBN 9789041128294
Published July 2009
Kluwer Law International
£125.00
Interpretation Double Taxation Conventions: General Theory and Brazilian Perspective ISBN 9789041128225
Published February 2009
Kluwer Law International
£173.00
Sales Taxation ISBN 9789065443816
Published January 2002
Kluwer Law International
£212.00
Taxation of Foreign Direct Investment ISBN 9789041197412
Published August 1999
Kluwer Law International
£183.00
The Impact of State Sovereignty on Global Trade and International Taxation ISBN 9789041197030
Published May 1999
Kluwer Law International
£177.00
Multilateral Tax Treaties ISBN 9789041107046
Published June 1998
Kluwer Law International
£220.00
The Improper Use of Tax Treaties ISBN 9789041107374
Published June 1998
Kluwer Law International
£253.00
Taxing Corporate Profits in the EU ISBN 9789041107039
Published September 1997
Kluwer Law International
£279.00
Tax Treatment of Financial Instruments ISBN 9789065446664
Published June 1995
Kluwer Law International
£300.00
Issues in International Partnership ISBN 9789065445773
Published July 1993
Kluwer Law International
£233.00
Permanent Establishment: Erosion of a Tax Treaty Principle ISBN 9789065445940
Published October 1991
Kluwer Law International
Out of print
Tax Treaties and EC Law
ISBN 9789041106803
Published November 1990
Kluwer Law International
£295.00
International Juridical Double Taxation of Income ISBN 9789065444264
Published September 1989
Kluwer Law International
£281.00
Nondiscrimination in International Tax Law ISBN 9789065442666
Published July 1988
Kluwer Law International
£273.00
Tax Co-ordination in the European Community
ISBN 9789065442727
Published March 1987
Kluwer Law International
£388.00
International Studies in Taxation
ISBN 9789041196927
Published December 1968
Kluwer Law International
£253.00
Towards Corporate Tax Harmonization in the European Community
Adolfo J. Martin JimenezAssociate Professorr of Tax Law, University of Cadiz Law School, Jerez de la Frontera, Spain
ISBN 9789041196903
Published December 1968
Kluwer Law International
£296.00