CIAT Manual for the Control of International Tax Planning: Section 3.5 Hybrids

The CIAT Executive Secretariat is pleased to invite you to download and read section 3.5 of the Manual for the Control of International Tax Planning, 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. This document is available in Spanish and English.

The author of this section is Mr. David Vilches de Santos, an official of the Spanish Tax Administration (AEAT).

This is the sixth document published within the framework of the CIAT-GIZ-EUROsociAL+ Manual for the Control of International Tax Planning in the current year.

The complete Manual has 6 chapters made up of 42 sections. New sections will be published soon.



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