Hybride Gesellschaften im Internationalen Steuerrecht der Bundesrepublik Deutschland

This book’s topic is one of the most complex and highly debated issues in international tax law. The basis of the analysis is provided by identifying three main problems and uncertainties when dealing with hybrid entities. By means of these, the author systemises and subsequently analyses the broad range of opinions on the correct taxation of those companies with regard to the most effective and targeted measure. In this context, the OECD BEPS-projects’ outcome also receives some attention. Thereby, the reader is provided with a well-sorted overview on the main opinions debated during the last decades and is enabled to critically evaluate the latest reform proposals.
Based on the detected advantages and shortcomings of each of the analysed approaches, the author proposes a new, subtle system of regulations.