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

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.