Download the fantastic book titled Hybrid Entities in Tax Treaty Law written by Sriram Govind, available in its entirety in both PDF and EPUB formats for online reading. This page includes a concise summary, a preview of the book cover, and detailed information about "Hybrid Entities in Tax Treaty Law", which was released on 03 September 2020. We suggest perusing the summary before initiating your download. This book is a top selection for enthusiasts of the Law genre.
Summary of Hybrid Entities in Tax Treaty Law by Sriram Govind PDF
Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.
Detail About Hybrid Entities in Tax Treaty Law PDF
- Author : Sriram Govind
- Publisher : Linde Verlag GmbH
- Genre : Law
- Total Pages : 696 pages
- ISBN : 3709410754
- Release Date : 03 September 2020
- PDF File Size : 15,7 Mb
- Language : English
- Rating : 4/5 from 21 reviews
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