4.3. Anti-hybrid regimes


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, in this opportunity, Mr. David Vilches de Santos, an official of the State Agency of Tax Administration (AEAT) of Spain, complements section 3.5 ‘Hybrids’ disseminated last week by this means. The referred section 3.5. presents the main tax effects of hybrid figures, while section 4.3. describes and comments on a series of useful measures to address and counteract the harmful effect of tax hybrids.

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