Hybrid mismatch arrangement and IRO: Difference between pages

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imported>Doug Williamson
(Create the page. Source: Mazars http://blogs.mazars.com/letstalktax/2016/01/hmrc-issues-examples-of-hybrid-mismatch-rules/)
 
imported>Doug Williamson
(Classify page.)
 
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''Tax''.
Interest Rate Option.


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.
== See also ==
* [[Interest rate option]]


 
[[Category:Financial_products_and_markets]]
Following OECD and G20 initiatives in relation to tax base erosion and profit shifting, the UK has 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]]
* [[Fixed-ratio method]]
* [[G20]]
* [[Hybrid]]
* [[Multinational corporation/company]]
* [[OECD]]
* [[Worldwide interest cap]]
* [[Tax avoidance]]
* [[Transfer pricing]]
* [[Double taxation]]
 
 
===Other links===
 
*[[Media:BEPS_report_2013.pdf|OECD Action Plan on Base Erosion and Profit Shifting 2013]]
*[[Media:2015_10_Oct_-_Walk_the_line.pdf| Walk the line, The Treasurer, 2015]]

Revision as of 12:51, 26 June 2022

Interest Rate Option.


See also