Hybrid Mismatches and the BEPS Project: A Spanish Perspective on Brazilian Juros

Journal
Author
Lorán Meler, M.; Villa, E.
Country
Spain
Published Date
Issue
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2017 (Volume 19), No. 2
FormatPDF
EUR
45
| USD
50 (VAT excl.)

After providing background on the treatment of hybrid mismatches under the BEPS project, the authors discuss treatment of Brazilian juros under both domestic law and the applicable income tax treaty. Rulings by Spanish courts on this subject are also analysed.