Essays about: "Hybrid Mismatch Arrangements"

Found 3 essays containing the words Hybrid Mismatch Arrangements.

1. 1. Hybrid Mismatch Arrangements Within EU: Under what Conditions could Single Taxation Be Secured?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Margret Agusta Sigurdardottir; [2016]
   Keywords : Tax; Taxation; Tax Law; Direct Taxation; Fundamental Freedoms; Double Taxation; Double Non-Taxation; Tax Avoidance; Aggressive Tax Planning; The Single Tax Principle; Single Taxation; Tax Treaty Law; GAAR; General Anti-Abuse Rule; Exemption Method; Credit Method; Dividend; Interest; Classification of Income; International Tax Regime; ECJ Case Law; Hybrid Mismatch Arrangements; Hybrid Financial Instruments; Parent-Subsidiary Directive; Base Erosion and Profit Shifting; BEPS; BEPS Action Plan 2; Anti-Hybrid Rules; Linking Rules; Correspondence Principle; Anti-Tax Avoidance Directive Proposal; Parent-Subsidiary Directive Amendments; Justification Grounds; EU Law; Law and Political Science;

   Abstract : The purpose of the thesis is to analyse the problems of hybrid mismatch arrangements within the EU and how single taxation, which requires income to be taxed once, not more or less, can be secured under EU law. After the amendments of the Parent-Subsidiary Directive (PSD), where an anti-hybrid rule was enacted, the legal environment for companies within the European Union changed. READ MORE

3. 2. Neutralizing the Effects of Hybrid Mismatch Arrangements on a EU Level - To what extent can Member States be obliged to align their tax systems to each other?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Juliane Fiebig; [2016]
   Keywords : Hybrid Mismatches; Hybrid Financial Instruments; Double Taxation; Double Non-Taxation; Tax Abuse; BEPS; Anti-Tax Tax Avoidance; Tax Arbitrage; Law and Political Science;

   Abstract : Due to the on-going discussion regarding the OECD/G20 BEPS project and its particular actions it is an important task for the EU legislator to establish a reasonable and functional legal framework in order to ensure a certain degree of uniformity of Anti-BEPS measures within the European Union. In doing so, the protagonists must respect the boundaries set to domestic law as well as to measures of secondary legislation by primary EU law. READ MORE

4. 3. Assessment of "Anti-Hybrid" Approach to the Problem of Aggressive Tax Planning in the light of the European Commission’s proposal to amend Article 4(1)(a) of the Parent-Subsidiary Directive

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Nataliya Strelnikova; [2014]
   Keywords : Interest and Royalties Directive; Parent-Subsidiary Directive; switch-over clause; OECD Model; double dip phenomenon; aggressive tax planning; mismatch arrangements; legal pluralism; conflict of classification; hybrid financial instruments; profit distribution; autonomous definition; freedom of establishment; abuse of law; Law and Political Science;

   Abstract : Hybrid mismatch arrangements, which exploit differences in the tax treatment of dividends and interest as well as differences in the classification of financial instruments between two or more countries, have been found to be a widely used tool in aggressive tax planning since multinational companies using hybrid financial instruments could benefit from the “double dip” phenomenon. This issue has been in the spotlight on different levels. READ MORE