Hybrid mismatch arrangement: Difference between revisions

From ACT Wiki
Jump to navigationJump to search
imported>Doug Williamson
(Mend link.)
(Remove out of date material.)
 
(5 intermediate revisions by one other user not shown)
Line 4: Line 4:
*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.
Line 13: Line 14:
==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]]
Line 21: Line 22:
* [[G20]]
* [[G20]]
* [[Hybrid]]
* [[Hybrid]]
* [[Hybrid capital]]
* [[Hybrid entity]]
* [[Hybrid entity]]
* [[Multinational corporation/company]]
* [[Multinational corporation/company]]
* [[OECD]]
* [[Organisation for Economic Co-operation and Development]] (OECD)
* [[Tax avoidance]]
* [[Tax avoidance]]
* [[Transfer pricing]]
* [[Transfer pricing]]
Line 29: Line 31:




==Other resource==


===Other links===
*[[Media:2015_10_Oct_-_Walk_the_line.pdf| Walk the line, The Treasurer, 2015]]


*[[Media:BEPS_report_2013.pdf|OECD Action Plan on Base Erosion and Profit Shifting 2013]]
[[Category:Accounting,_tax_and_regulation]]
*[[Media:2015_10_Oct_-_Walk_the_line.pdf| Walk the line, The Treasurer, 2015]]

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