Taxation of Cross-border Partnerships

Taxation of Cross-border Partnerships

Double Tax Relief in Hybrid and Reverse Hybrid Situations

by Jesper Barenfeld

406 pages· 2005· ISBN 9789076078854
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Aims to identify and analyse problems related to double taxation of income attributable to cross border partnerships in asymmetrical situations de lege lata. This refers to cases where the same partnership, in across border owner/entity situation, is recognized as a taxable person in one country, but as transparent for tax purposes in the other."

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