The Resource Hybrid entity mismatches : exploring three alternatives for coordination

Hybrid entity mismatches : exploring three alternatives for coordination

Label
Hybrid entity mismatches : exploring three alternatives for coordination
Title
Hybrid entity mismatches : exploring three alternatives for coordination
Creator
Subject
Language
eng
Summary
The article discusses OECD pragmatic approach regarding hybrid entity mismatches. It argues for coordination in the tax characterization of entities as a straightforward and suitable alternative to replace the current OECD linking rules, and perhaps also, the consequentialist OECD approach to hybrid entity mismatches. For this purpose, three specific alternatives are explored for coordination in the tax characterization of entities, which include (1) supremacy of the tax characterization rules of the source state, (2) supremacy of the tax characterization rules of the residence state and (3) supremacy of the tax characterization rules of the home state. The analysis of these alternatives includes both hypotheticals and specific examples from domestic and supranational laws that are used to illustrate and support their effectiveness. The author demonstrates that coordination in the tax characterization of entities appears to be not only a more preferable path when compared to the OECD approach of matching tax outcomes, but also a more coherent and less costly alternative for both taxpayers and tax administrations
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 47 (2019), no. 1 ; p. 24-54
http://library.link/vocab/creatorName
Parada, L
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • hybrid entity
  • hybrid mismatch
  • entity classification
  • linking rules
Label
Hybrid entity mismatches : exploring three alternatives for coordination
Instantiates
Publication
Label
Hybrid entity mismatches : exploring three alternatives for coordination
Publication

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