The OECD Model (2017) and Hybrid Entities: Some Opaque Issues and Their Transparent Solutions

Journal
Jain, K.
International; OECD
Bulletin for International Taxation 2019 (Volume 73), No. 3
Format/Price
JournalUSD 45

This article considers the provisions introduced by way of article 1(2) of the OECD Model (2017) to address issues relating to hybrid entities, how successful the OECD has been in resolving these problems and the further matters that arise as a result of the new provisions.