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Hybrid Entities and the EU Direct Tax Directives

Edited by G.K. Fibbe, A. J. A. Stevens


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EUCOTAX Series on European Taxation Volume 41

Hybrid Entities and the EU Direct Tax Directives is the first ever book on tax issues in multiple EU Member States involving the application of the EU Direct Tax Directives and hybrid entities.

Benefit from the detailed analysis, ranging from specific national law developments to solidly grounded recommendations, offering unprecedented guidance on the way forward. Opening with a general background describing the EU framework in the introduction and concluding with a comparative analysis incorporating concrete recommendations, you’ll gain a full understanding of the issues and potential solutions. The main body consists of reports by local experts from eight Member States – Austria, Belgium, Denmark, France, Germany, Italy, Luxembourg, and the Netherlands. Each country report quickly brings you up to date with practice in that country, with discussion of the national system for classifying foreign entities and how the specific country applies the interwoven impacts of the following factors on issues relating to hybrid entities.

The final recommendations include ‘linking rules’ that serve to align Member States’ direct tax systems with stringent entity classifications and allocation of income, effectively neutralizing the effects of hybrid mismatches.

How will this improve your practice?

  • Crystallize the issues surrounding tax treatment of hybrid entities allowing you navigate the field with confidence.
  • Be prepared for obstacles with in-depth analysis of problems arising from autonomous tax classification of hybrid entities.
  • Learn the full scope and range of how hybrid entities are treated at all levels.
  • Employ legal strategies based on solidly grounded tax expert recommendations.

Individual country reports contain all the information you need by including coverage of the below and more:

  • Primary EU law and relevant case law of the ECJ;
  • EU Parent-Subsidiary Directive;
  • EU Merger Directive;
  • EU Interest and Royalty Directive;
  • OECD tax treaty approach to hybrid entities.

Hybrid Entities and the EU Direct Tax Directives will be welcomed by tax practitioners advising multinationals, and will also be of great value to academics and government officials in any country dealing with EU or Member State tax law.

Resources Table of Contents
Pages 312
Last Updated 12/29/2014
Update Frequency As Needed
Product Line Kluwer Law International
ISBN 9789041159427
SKU 10059172-0001
Table of Contents

About the Editors.


Chapter 1 Introduction.

Part I The EU and OECD Approach to Hybrid Entities.

Chapter 2 The Approach to Hybrid Entities under Primary EU Law and in the EU Tax Directives.

Chapter 3 The Approach to Hybrid Entities under the OECD Model Tax Convention.

Part II Country Chapters.

Chapter 4 Introduction.

Chapter 5 Austria Yvonne Schuchter-Mang.

Chapter 6 Belgium Bart Peeters.

Chapter 7 Denmark Søren Jesper Hansen and Steff Fløe Pedersen .

Chapter 8 France Allard de Waal en Laurent Ragot.

Chapter 9 Germany Sven Fuhrmann and Johannes Huken.

Chapter 10 Italy Stefano Grilli.

Chapter 11 Luxembourg Peter Adriaansen, Frank van Kuijk and Mélanie Staes.

Chapter 12 The Netherlands Gijs K. Fibbe and Ton A.J. Stevens.

Part III Comparative Analysis, Conclusions and Recommendations.

Chapter 13 Comparative Analysis, Conclusions and Recommendations Gijs K. Fibbe and Ton A.J. Stevens.


List of Abbreviations.