What is meant by Hybrid Mismatch Arrangement? What are the ways in which hybrid mismatch arrangements are used to achieve unintended double…

CA Final · Direct Tax Laws and International Taxation · PYQS · November 2024
What is meant by Hybrid Mismatch Arrangement? What are the ways in which hybrid mismatch arrangements are used to achieve unintended double non-taxation or long-term tax deferral in one or more of the following ways?

Suggested Answer and Working Notes:

(ii) A hybrid mismatch is an arrangement that exploits a difference in the tax treatment of an entity or an instrument under the laws of two or more tax jurisdictions to achieve double non-taxation. Hybrid mismatch arrangements are sometimes used to achieve unintended double non-taxation or long-term tax deferral in one or more of the following ways Creation of two deductions for a single borrowalGeneration of deductions without corresponding income inclusionsMisuse of foreign tax creditParticipation exemption regimes

Topics: Fundamentals of BEPS

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