Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary f

Double non-taxation stemming from hybrid financial instruments and the solutions provided by the OECD and the European Union for tackling such an outcome are th

An in-depth analysis of various aspects of multilateral cooperation in tax law Tax evasion and aggressive tax planning causing base erosion and profit shifting

The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to intern

Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and e