Hybrid Entities in Tax Treaty Law

S. 3041. Preliminary Remarks

Investment funds have played a large part in the world economy for several decades. Its majority is much more than the digital economy. While the value of the platform companies of the digital economy was estimated at more than $7 trillion in 2017, the total assets of worldwide funds was estimated at $49.3 trillion in 2017 and $46.7 in 2018.

Primarily, collective investment funds should be distinguished from investment funds. Investment funds provide broad and different opportunities, management expertise, benefiting scale of economy and low investment cost to investors. Collective investment fund, mutual funds, exchange-traded funds, sovereign wealth funds, money market funds and hedge funds are some of types of investment funds. In these cases, collective investment funds are termed collective investment vehicle(CIV). Although there are some different regulations of defining the types of investment funds based on domestic laws of countries, in this article we consider OECD's definition for collective investment vehicles because we examine the tax treatment of collective investment vehicles(CIV) under the OECD Model Convention(OECD MC). With that, this definit...