BEPS Impact on EU Law: Hybrid Payments and Abusive Tax Behaviour

E. Kokolia · Evgenia Chatziioakeimidou

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Taxation and Legal Issues Corporate Taxation and Avoidance EU Law and Policy Analysis

Abstract

The authors, in this article, analyse the OECD’s deliverables from 16 September 2014 on Action 2, “Neutralising the effects of Hybrid Mismatch Arrangements” and Action 6 on “Preventing the Granting of Treaty Benefits in Inappropriate Circumstances”, as well as recently adopted relevant EU legislation. The authors consider whether targeted measures are necessary at the EU level to incorporate solutions proposed at the OECD level in order to tackle aggressive tax planning and corporate tax avoidance.

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References

2015Aggressive Tax Planning in EU Law and in the Light of BEPS: The EC Recommendation on Aggressive Tax Planning and BEPS Actions 2 and 6 2013Abuse of Law in European Tax Law: An Overview and Some Recent Trends in the Direct and Indirect Tax Case Law of the ECJ – Part 1 2014Where is EU Law in the OECD BEPS Discussion?2011The General Anti-Abuse Rule of Article 80 of the Draft Proposal for a Council Directive on a Common Consolidated Corporate Tax Base

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2017Tax Competition and Tax Coordination in Aggressive Tax Planning: A False Dichotomy

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