Clifford Chance

BEPS – practical impact of the hybrid and tax treaties proposals on funds, corporate groups, financial institutions and SPVs - September 2014

17 September 2014

On 16 September the OECD published the first set of seven recommendations under the Base Erosion and Profit Shifting (BEPS) project. Two will have particularly wide implications: hybrids (Action 2) and tax treaty abuse (Action 6).  These proposals are not yet law, but some version of them is likely to be implemented fairly soon by many countries.  We ask: What will the practical impact be? And what steps should be taken now to anticipate and mitigate the impact?

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