La doble no imposición como resultado de la utilización de instrumentos y entidades híbridas

Resumo

This investigation is aimed at the study of the double non-taxation as a result of the use of hybrid entities and hybrid financial instruments. This investigation is framed within the context of a phenomenon that has earned great importance lasts years: aggressive tax planning. In globalized environment, big companies have become multinational, thus giving rise to new challenges for the international tax regime. Divergences between different domestic tax systems in an international setting have offered mechanisms to multinational companies to reduce their tax costs...