About this book: Double Non-taxation and the Use of Hybrid Entities provides a critical review of the Economic Co-operation and Developments (OECDs) approach in Base Erosion and Profit Shifting (BEPS) Action 2 and proposes a deeply informed alternate method based on the tax policy aims of simplicity, coherence and ease of administration. The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations within the tax world seem to be leading to an international commitment most materially manifested in the OECD BEPS project. This book provides a consistent option to address the issues of hybrid entity mismatches, which may be used as a point of comparison with regard to the curre
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