The OECD Model (2017) and Hybrid Entities: Some Opaque Issues and Their Transparent Solutions
Journal
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2019 (Volume 73), No. 3
Document
This article considers the provisions introduced by way of article 1(2) of the OECD Model (2017) to address issues relating to hybrid entities, how successful the OECD has been in resolving these problems and the further matters that arise as a result of the new provisions.