The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to intern

Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and e

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 l

Aims to identify and analyse problems related to double taxation of income attributable to cross border partnerships in asymmetrical situations de lege lata. Th

Hybrid entities give rise to international tax problems, and it must be acknowledged, opportunities. Why is this so? This is because, at the heart of the phenom