Spain - Hybrid Mismatches and the BEPS Project: A Spanish Perspective on Brazilian Juros
- M. Loran; E. Villa
- Derivatives & Financial Instruments, 2017 (Volume 19), No 2
- 10 April 2017
After providing background on the treatment of hybrid mismatches under the BEPS project, the authors discuss treatment of Brazilian juros under both domestic law and the applicable income tax treaty. Rulings by Spanish courts on this subject are also analysed.