Hybrid mismatch arrangement: Difference between revisions
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Following OECD and G20 initiatives in relation to tax base erosion and profit shifting, the UK | Following OECD and G20 initiatives in relation to tax base erosion and profit shifting, the UK introduced anti-hybrid tax rules, effective from 2017. | ||
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* [[Corporation Tax]] | * [[Corporation Tax]] | ||
* [[Diverted profits tax]] | * [[Diverted profits tax]] | ||
* [[Double taxation]] | |||
* [[Fixed-ratio method]] | * [[Fixed-ratio method]] | ||
* [[G20]] | * [[G20]] | ||
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* [[Multinational corporation/company]] | * [[Multinational corporation/company]] | ||
* [[OECD]] | * [[OECD]] | ||
* [[Tax avoidance]] | * [[Tax avoidance]] | ||
* [[Transfer pricing]] | * [[Transfer pricing]] | ||
* [[ | * [[Worldwide interest cap]] | ||
Revision as of 10:50, 10 January 2018
Tax.
A hybrid mismatch arrangement is an arrangement:
- Intended to secure a tax advantage within a multinational group
- Resulting from a difference in tax treatment of the same financial instrument or entity between different jurisdictions.
Hybrid mismatch arrangements can arise both from hybrid financial instruments and from hybrid entities.
Following OECD and G20 initiatives in relation to tax base erosion and profit shifting, the UK introduced anti-hybrid tax rules, effective from 2017.
See also
- Base erosion and profit shifting
- CbC reporting
- Common Consolidated Corporate Tax Base
- Corporation Tax
- Diverted profits tax
- Double taxation
- Fixed-ratio method
- G20
- Hybrid
- Hybrid entity
- Multinational corporation/company
- OECD
- Tax avoidance
- Transfer pricing
- Worldwide interest cap
