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Contribution Details

Type Bachelor's Thesis
Scope Discipline-based scholarship
Title Hybrid Entities in the OECD BEPS Report: Consequences for Switzerland and Russia
Organization Unit
Authors
  • Sergey Ryabikin
Supervisors
  • Kjell G. Nyborg
Language
  • English
Institution University of Zurich
Faculty Faculty of Economics, Business Administration and Information Technology
Number of Pages 45
Date 2014
Abstract Text The thesis defines hybrid entities (HE), describes their nature and analyses prerequisites for HE existence. Further, various effects resulting from application of HE, such double non-taxation, double deduction, tax deferral or double taxation are presented and analysed. Additionally the position of OECD on Hybrid mismatch arrangements is summarised and discussed. The practical part highlights the relevant national taxation principles, explores practical approach to taxation of hybrids in Switzerland and Russia and provides a short comparison of the two approaches.
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