Research report 2015 - Max Planck Institute for Tax Law and Public Finance
The phenomenon of double non-taxation: An analysis in light of the (ab)use of hybrid entities
Abteilung für Unternehmens- und Steuerrecht
SummaryA project at the Max Planck Institute for Tax Law and Public Finance intends to clarify the phenomenon of double non-taxation and to advocate for its neutrality as an objective outcome. Using hybrid entities as an example of analysis, this work aims to demonstrate that the sole result of non-taxation should not be a matter of concern in any cross-border transaction. Instead, the real target should be in determining whether the natural disparities between tax legislations can be subject to abuse, and if so, how to counteract it.