Hybrid Mismatches

Action 2 and the Multilateral Instrument

Lui Eduardo Schouen & Guilherme Galdino

In order to address tax arbitrage on hybrid mismatch, Action 2 of the Action Plan on BEPS requires coordination on the modification of both domestic provisions and tax treaties. The authors describe Articles 3, 4 and 5, and test such coordination. [read]

 

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