Hybrid mismatch arrangement: Difference between revisions

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imported>Doug Williamson
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*Intended to secure a tax advantage within a multinational group
*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.
*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.
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 has introduced anti-hybrid tax rules, effective from 2017.
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==
==See also==
* [[Base erosion and profit shifting]]
* [[Base erosion and profit shifting]]
* [[Business in Europe: Framework for Income Taxation]]
* [[CbC reporting]]
* [[CbC reporting]]
* [[Common Consolidated Corporate Tax Base]]
* [[Corporation Tax]]
* [[Corporation Tax]]
* [[Diverted profits tax]]
* [[Diverted profits tax]]
* [[Fixed-ratio method]]
* [[Double taxation]]
* [[Fixed ratio method]]
* [[G20]]
* [[G20]]
* [[Hybrid]]
* [[Hybrid]]
* [[Hybrid capital]]
* [[Hybrid entity]]
* [[Multinational corporation/company]]
* [[Multinational corporation/company]]
* [[OECD]]
* [[Organisation for Economic Co-operation and Development]] (OECD)
* [[Worldwide interest cap]]
* [[Tax avoidance]]
* [[Tax avoidance]]
* [[Transfer pricing]]
* [[Transfer pricing]]
* [[Double taxation]]
* [[Worldwide interest cap]]




===Other links===
==Other resource==


*[[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]]
*[[Media:2015_10_Oct_-_Walk_the_line.pdf| Walk the line, The Treasurer, 2015]]
[[Category:Accounting,_tax_and_regulation]]

Latest revision as of 04:26, 8 February 2024

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


Other resource