BEPS Hybrid Entities Proposal: A Slippery Slope, Especially for Developing Countries

7 Pages Posted: 12 Feb 2017 Last revised: 27 Feb 2017

See all articles by Dhruv Sanghavi

Dhruv Sanghavi

affiliation not provided to SSRN

Date Written: 2017

Abstract

Two principle purposes of the OECD/G20 BEPS project can be identified: First, to combat against aggressive tax planning which results in less than single taxation, and secondly, to allocate taxing rights to the state in which the economic activity gives rise to income. This note demonstrates that Article 1(2) tends to enable diametrically opposite results.

Keywords: BEPS, Partnerships, Hybrid Entities, OECD, G20, United Nations, Model Tax Convention, Multilateral Instrument

Suggested Citation

Sanghavi, Dhruv, BEPS Hybrid Entities Proposal: A Slippery Slope, Especially for Developing Countries (2017). Tax Notes International, Vol. 85, No. 4, 2017, Available at SSRN: https://ssrn.com/abstract=2915454 or http://dx.doi.org/10.2139/ssrn.2915454

Dhruv Sanghavi (Contact Author)

affiliation not provided to SSRN

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