Hybrid Entities in Tax Treaty Law

S. VIIPreface

This volume in the “Series on International Tax Law” includes the master’s theses of the full-time students attending the 2019-20 class of the postgraduate LL.M. programme in International Tax Law at WU (Vienna University of Economics and Business). The general topic for this year is “Hybrid entities in tax treaty law”. Just as tax avoidance has been a topic in vogue for the past few decades, aggressive tax planning involving exploitation of differences in the tax treatment of entities in two or more jurisdictions leading to the erosion of the tax base of jurisdictions has also been gaining significance in academic and tax policy related discussions. This is particularly relevant in the case of hybrid entities that are classified differently for tax purposes in different jurisdictions. These discussions were amplified owing to the OECD/G-20 Base Erosion and Profit Shifting (BEPS) Project in which, as part of Action Plan 2, recommendations were made regarding the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of hybrid mismatch arrangements.

Against this background, given the importance of a comprehensive analysis of the...