The topics of double non-taxation and hybrid entities have acquired a particular importance in a context where transformations within the tax world seem to be leading to an international commitment most materially manifested in the OECD Base Erosion and Profit Shifting (BEPS) project. In this...

This chapter analyses the recent modifications to the 2017 OECD Model Tax Convention as regards fiscally transparent entities. The ultimate aim of the Chapter is to determine how these modifications have impacted the dynamic of granting or denying tax treaty benefits and whether these changes...

The world appears to have officially embraced the altruistic idea of ensuring a minimum level of corporate income taxation worldwide, aiming to reduce tax competition and to protect the interests of both developed and developing countries. However, this ‘benefits for all’ narrative proves to...

This article argues that the “saving clause” provision introduced in the 2017 OECD Model conflicts with the entitlement to double taxation relief under Article 23 OECD Model, especially in cases involving the use of hybrid entities. Although this issue is pragmatically solved in the new...

This contribution analyses the complexities and potential unintended outcomes that derive from the interaction between the GloBE rules and tax neutral regimes, namely regimes that ensure a single level of taxation at the level of the owners of an entity. Most notably, this chapter argues that...