Base Erosion and Profit Shifting: A Roadmap for Reform – Tax Arbitrage with Hybrid Instruments

Journal
OECD; United Kingdom
Bulletin for International Taxation 2014 (Volume 68), No. 6/7
This article considers the interaction between the OECD BEPS initiative on tax arbitrage with hybrid instruments and domestic measures that either create the potential for mismatches or already address the issues that arise. The article examines the relevant philosophical and practical issues regarding this topic and suggests some potential solutions.