The Resource BEPS - impact of hybrid and tax treaties proposals

BEPS - impact of hybrid and tax treaties proposals

Label
BEPS - impact of hybrid and tax treaties proposals
Title
BEPS - impact of hybrid and tax treaties proposals
Creator
Subject
Language
eng
Summary
Of the recently published OECD recommendations as part of the base erosion and profit shifting (BEPS) Action Plan, some have potentially wider significance than others for multinationals, corporates and financial institutions. This article looks at the implications of the most wide reaching changes, and practical steps to be taken to prepare for and mitigate risk. The article looks at (I) Action 6 - treaty abuse: a. What is it all about? b. What will be affected? c. Who will be affected? d. How does the purpose test work? e. How does the limitation of benefits (LOB) work?; (II) Impact of treaty proposals on funds and special purpose vehicles (SPVs), (III) Action 2 - hybrids: a. What is it all about? b. What will be affected? c. Who will be affected? d. How will the rules apply? e. Other recommendations, f. What should you be doing? and (V) What happens next?
Citation source
In: Tax planning international : European tax service. - London. - Vol. 16 (2014),
http://library.link/vocab/creatorName
Niedle, D
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • BEPS Project (OECD)
  • tax treaty
  • treaty shopping
  • hybrid entity
Label
BEPS - impact of hybrid and tax treaties proposals
Instantiates
Publication
Label
BEPS - impact of hybrid and tax treaties proposals
Publication

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