The Resource BEPS Action 2 : trusts as hybrid entities

BEPS Action 2 : trusts as hybrid entities

Label
BEPS Action 2 : trusts as hybrid entities
Title
BEPS Action 2 : trusts as hybrid entities
Creator
Subject
Language
eng
Summary
This article considers the application of BEPS Action 2 to trust-based hybrid mismatches. It demonstrates that the recommendations in the BEPS Action 2 Report do not address trust mismatches in a sensible and systematic way. Trust mismatches should be the subject of further work to develop rules that deal properly with issues arising from the particular characteristics of trusts and trust taxation. These include recognition of grantor/settlor taxation, trust-specific conflicts of attribution and residence, the utility or otherwise of considering deductibility in addition to non-taxation of trust income, and the reconciliation of corporate and transparent taxing paradigms. In this analysis, the domestic tax laws of Australia, USA, UK and New Zealand have been considered in particular for context and background
Citation source
In: British tax review. - London. - (2018), no. 2 ; p. 211-242
http://library.link/vocab/creatorName
Brabazon, M.L
Geographic coverage
  • International
  • Pacific Islands
  • European Union
  • Europe
  • North America
Language note
English
http://library.link/vocab/subjectName
  • trust
  • hybrid mismatch
  • BEPS Action Plan
  • tax arbitrage
  • domestic tax law
  • hybrid entity
  • attribution of profits
  • residence
  • entity classification
  • transparency
Label
BEPS Action 2 : trusts as hybrid entities
Instantiates
Publication
Label
BEPS Action 2 : trusts as hybrid entities
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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