Scheffler W, Kohl M (2018)
Publication Type: Journal article
Publication year: 2018
Book Volume: 70
Journal Issue: 6
The Anti-Tax-Avoidance Directive (ATAD) has introduced complex rules against hybrid mismatch arrangements for the EU. Which of the rules apply will depend on the type of hybrid mismatch arrangement as well as the legal characterization of an entity. As the ATAD does not neutralise the differences between the taxation of equity capital and debt capital, there is still room for tax planning. By adjusting the (intracompany) external financing, the additional tax burden caused by ATAD can be limited to the tax rate applicable to the lowest-taxed entity. With regard to the objective of the BEPS initiative, it is worth mentioning that low-tax countries benefit most from the anti-abuse measures for hybrid mismatch arrangements.
APA:
Scheffler, W., & Kohl, M. (2018). Hybrid Mismatch Rules: Countries with low tax rates are the winners. Betriebswirtschaftliche Forschung und Praxis, 70(6).
MLA:
Scheffler, Wolfram, and Manuela Kohl. "Hybrid Mismatch Rules: Countries with low tax rates are the winners." Betriebswirtschaftliche Forschung und Praxis 70.6 (2018).
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