The Resource Cross-border intra-group hybrid finance : a comparative analysis of the legal approach adopted by Brazil, the United Kingdom and the United States

Cross-border intra-group hybrid finance : a comparative analysis of the legal approach adopted by Brazil, the United Kingdom and the United States

Label
Cross-border intra-group hybrid finance : a comparative analysis of the legal approach adopted by Brazil, the United Kingdom and the United States
Title
Cross-border intra-group hybrid finance : a comparative analysis of the legal approach adopted by Brazil, the United Kingdom and the United States
Creator
Subject
Language
eng
Summary
The article analyses how Brazil, the United Kingdom and the United States are dealing with the use of hybrid financing. The purpose is to verify whether or not a comprehensive approach in countering tax avoidance in intra-group finance could be adopted and to what extent it would be effective
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 67 (2013),
http://library.link/vocab/creatorName
Bispo, R. Minervino
Language note
English
http://library.link/vocab/subjectName
  • hybrid financing
  • tax avoidance
  • intra-group financing
  • tax arbitrage
  • Parent-Subsidiary Directive
  • Interest and Royalties Directive
  • US Model
  • OECD Model
  • source of income
Label
Cross-border intra-group hybrid finance : a comparative analysis of the legal approach adopted by Brazil, the United Kingdom and the United States
Instantiates
Publication
Label
Cross-border intra-group hybrid finance : a comparative analysis of the legal approach adopted by Brazil, the United Kingdom and the United States
Publication

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