Hybrid Mismatch Arrangements: OECD Recommendations and German Practice

Journal
Germany; OECD
Bulletin for International Taxation 2013 (Volume 67), No. 10
Against the background of the various recent OECD reports on base erosion and profit shifting, the authors investigate the tax classifications of financial instruments and entities in selected EU Member States and OECD member countries, and examine German tax rules that deal with the consequences of different tax classifications.