Cross-Border Intra-Group Hybrid Finance: A Comparative Analysis of the Legal Approach Adopted by Brazil, the United Kingdom and the United States

Journal
Author
Bispo, R.M.
Country
Brazil; United Kingdom; United States
Published Date
Issue
Bulletin for International Taxation 2013 (Volume 67), No. 7
FormatPDF
EUR
45
| USD
50 (VAT excl.)

The article analyses how Brazil, the United Kingdom and the United States are dealing with the use of hybrid financing. The purpose is to verify whether or not a comprehensive approach in countering tax avoidance in intra-group finance could be adopted and to what extent it would be effective.