Cross-Border Intra-Group Hybrid Finance: A Comparative Analysis of the Legal Approach Adopted by Brazil, the United Kingdom and the United States

Journal
Bispo, R.M.
Brazil; United Kingdom; United States
Bulletin for International Taxation 2013 (Volume 67), No. 7
PriceUSD 45

The article analyses how Brazil, the United Kingdom and the United States are dealing with the use of hybrid financing. The purpose is to verify whether or not a comprehensive approach in countering tax avoidance in intra-group finance could be adopted and to what extent it would be effective.