Essays about: "Hybrid Mismatches"

Found 3 essays containing the words Hybrid Mismatches.

1. 1. 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

3. 2. 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

4. 3. An idea whose time has come : an innovation perspective on Marine Spatial Planning

   University essay from Stockholm Resilience Centre

   Author : Andrew Merrie; [2011]
   Keywords : Social-Ecological System; Innovation; Diffusion; Agency; Networks; Marine Spatial Planning; Sustainability;

   Abstract : This study considers the emergence of Marine Spatial Planning as a tool for ecosystem-basedmanagement using an innovation diffusion perspective that combines elements of classical diffusionof innovations theory with a consideration of individual and networked agency and cross-scaledynamics in the context of a social-ecological systems perspective. The main findings are that thediffusion of Marine Spatial Planning does not follow a linear, technologically deterministic process asindicated by many diffusion of innovation studies but instead the diffusion process can becharacterised by a hybrid diffusion system that cascades over a series of phases and where individualsembedded in informal networks play a key role in driving the emergence of Marine Spatial Planningacross scales. READ MORE