Hybrid entity mismatches : exploring three alternatives for coordination

Resource Information

The work Hybrid entity mismatches : exploring three alternatives for coordination represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Hybrid entity mismatches : exploring three alternatives for coordination

Creator

• Parada, L

Subject

• entity classification
• hybrid entity
• hybrid mismatch
• linking rules

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

Geographic coverage

International

Language note

English