The Resource ATAD 2's punishment of disregarded entities : potential Italian remedies for double taxation

ATAD 2's punishment of disregarded entities : potential Italian remedies for double taxation

Label
ATAD 2's punishment of disregarded entities : potential Italian remedies for double taxation
Title
ATAD 2's punishment of disregarded entities : potential Italian remedies for double taxation
Creator
Subject
Language
  • eng
  • eng
Summary
Among tax practitioners, the interrelationship between the EU anti-hybrid rules in ATAD 2 (2017/952) and the US "check-the-box" regulations have been a source of debate since the initial drafts of ATAD 2. The debate seems to have reached a dead end in respect of intercompany services remunerated on a "cost-plus" basis. This article, against this background, focusses on an actual case for the purpose of illustrating certain unreasonable effects produced by the Italian anti-hybrid legislation
Citation source
In: European taxation. - Amsterdam. - Vol. 61 (2021), no. 7 ; p. 285-290
http://library.link/vocab/creatorName
  • Catucci, N
  • Scimenes, F
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • ATAD 2
  • hybrid mismatch
  • double taxation
  • disregarded entity
  • check-the-box regulations
  • ruling
Label
ATAD 2's punishment of disregarded entities : potential Italian remedies for double taxation
Instantiates
Publication
Note
20210730
Other control number
et_2021_07_it_1.html
Label
ATAD 2's punishment of disregarded entities : potential Italian remedies for double taxation
Publication
Note
20210730
Other control number
et_2021_07_it_1.html

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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