Hybrid mismatches under the ATAD I and II G. K. ( Gijs ) Fibbe & A. J.A. ( Ton ) Stevens
By: Fibbe, Gijsbert Karel
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Contributor(s): Stevens, A. J. A.
Material type: 
ArticlePublisher: 2017Subject(s): ASIMETRÍAS HÍBRIDAS | IMPUESTOS | EVASION FISCAL | EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS | PREVENCIÓN | UNION EUROPEA | ELUSION FISCAL | LEGISLACION COMUNITARIA
In:
EC Tax Review v. 26, n. 3, June 2017, p. 153-166Summary: Both Anti-Tax Avoidance Directive (atad) 1 and 2 contain specific provisions to tackle hybrid mismatches. As a matter of principle it has been decided to not remove the cause of hybrid mismatches within the internal market butto counter only a few of the symptomsof hybrid mismatches. In this article the authors discuss both the measures from atad 1 and 2 regarding hybrid mismatches, mainlyfocussing on hybrid mismatches caused by the use of (reverse) hybrid entities. Overall, the approach chosen by the Council does seemto close many of the existing loopholes were hybrid mismatches are used. Main remaining question is whether all twenty-sevenMember States will be able to consistently implement the complex anti-mismatch rules. The authors see it as a missed chance that inthe ATAD it has not been decided to address the very cause of hybrid mismatches. Cases of double taxation and hybrid mismatches with individuals are disregarded.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| IEF | OP 2141-B/2017/3-6 (Browse shelf) | Available | OP 2141-B/2017/3-6 |
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| OP 2141-B/2017/3-3 Exit taxation | OP 2141-B/2017/3-4 The General Anti - Abuse Rule of the Anti - Tax Avoidance Directive | OP 2141-B/2017/3-5 CFC rules and Anti - Tax Avoidance Directive | OP 2141-B/2017/3-6 Hybrid mismatches under the ATAD I and II | OP 2141-B/2017/3-7 Taking EU fundamental freedoms seriously | OP 2141-B/2017/4-1 Towards a more coordinated approach of the relation between the taxpayerand tax administrations | OP 2141-B/2017/4-2 VAT effects of year - end transfer pricing adjustments |
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Both Anti-Tax Avoidance Directive (atad) 1 and 2 contain specific provisions to tackle hybrid mismatches. As a matter of principle it has been decided to not remove the cause of hybrid mismatches within the internal market butto counter only a few of the symptomsof hybrid mismatches. In this article the authors discuss both the measures from atad 1 and 2 regarding hybrid mismatches, mainlyfocussing on hybrid mismatches caused by the use of (reverse) hybrid entities. Overall, the approach chosen by the Council does seemto close many of the existing loopholes were hybrid mismatches are used. Main remaining question is whether all twenty-sevenMember States will be able to consistently implement the complex anti-mismatch rules. The authors see it as a missed chance that inthe ATAD it has not been decided to address the very cause of hybrid mismatches. Cases of double taxation and hybrid mismatches with individuals are disregarded.
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