3.5. Hybrids
| AUTHOR | |
|---|---|
| David Vilches de Santos | |
| lectronic document | |
| Spanish and English | |
| CIAT | August 2022 |
Contents note:
The CIAT Executive Secretariat is pleased to present a new chapter of the Manual for the Control of International Tax Planning, prepared by Mr. David Vilches de Santos, an official of the Spanish Tax Administration (AEAT), whose content includes a conceptual framework on the figures that constitute ‘hybrids’ and other related aspects, such as the main characteristics of a hybrid mismatch, tax deductions derived from the use of a hybrid instrument, and the analysis of the various types of hybrid operations.
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