3.5. Hybrids


David Vilches de Santos
lectronic document
Spanish and English
 CIAT August 2022

Contents note:

The CIAT Executive Secretariat is pleased to present a new chapter of the Manual for the Control of International Tax Planning, prepared by Mr. David Vilches de Santos, an official of the Spanish Tax Administration (AEAT),  whose content includes a conceptual framework on the figures that constitute ‘hybrids’ and other related aspects, such as the main characteristics of a hybrid mismatch, tax deductions derived from the use of a hybrid instrument, and the analysis of the various types of hybrid operations.

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