Hybrid entities and the EU direct tax directives

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.