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
Related Questions in this Topic
- Describe the three-tier structure for transfer pricing documentation mandated by BEPS Action Plan 13. Which provisions u...
- Explain the terms "Most Favored Nation" and "Base Erosion and Profit Shifting (BEPS)" with reference to the internationa...
- Examine and state the correctness or otherwise of each of the following in the context of BEPS Action Plan and Income-ta...
- What does a hybrid mismatch mean, and how is it different from a branch mismatch? Describe briefly the reasons of hybrid...
- Describe the three-tier structure for transfer pricing documentation mandated by BEPS Action Plan 13. Which provisions u...