Examples of using Hybrid mismatch in English and their translations into Swedish
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Colloquial
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Official
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Medicine
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Ecclesiastic
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Ecclesiastic
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Official/political
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Computer
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Programming
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Political
To the extent that a hybrid mismatch results in a relief for tax withheld at source on a payment derived from a transferred financial instrument to more than one of the parties involved,
These hybrid mismatch rules should not apply if the underlying return on the transferred instrument is included in the taxable income of one the parties involved as in that case they will be left in the same tax position
A hybrid mismatch also includes the transfer of a financial instrument under a structured arrangement involving a taxpayer where the underlying return on the transferred financial instrument is treated for tax purposes as derived simultaneously by more than one of the parties to the arrangement,
In the event that the payment giving rise to that hybrid mismatch also gives rise to a hybrid mismatch that is attributable to differences in the legal characterisation of a financial instrument
Reverse hybrid mismatches.
Hybrid mismatches with third countries*.
This Directive lays down rules against hybrid mismatches involving third countries.
Member States should consider the introduction of penalties against taxpayers that exploit hybrid mismatches.
Hybrid mismatches between Member States and third countries still need to be further examined.
Hybrid mismatches occur when countries have different rules for taxing certain income or entities.
A framework to tackle hybrid mismatches.
Rules on hybrid mismatches should address mismatch situations which are the result of conflicting tax rules of two(or more) jurisdictions.
The rules on hybrid mismatches in the CCCTB and CCTB are consistent with the rules in this Directive.
Furthermore, this Directive addresses hybrid mismatches involving permanent establishments,
It is necessary to cover all hybrid mismatches or related arrangements where at least one of the parties involved is a corporate taxpayer in a Member State.
It is therefore appropriate to cover hybrid mismatch arrangements between the taxpayer and its associated enterprises and hybrid mismatches resulting from a structured arrangement involving a taxpayer.
As part of the final compromise proposal for the Anti-Tax Avoidance Directive that was agreed on 20 June 2016, the ECOFIN Council issued a statement on hybrid mismatches.
Therefore, it is widely recognised that hybrid mismatches involving third countries should be countered as well.
2016/1164 as regards hybrid mismatches with third countries.
The Code of Conduct Group on Business Taxation has agreed on guidance to tackle various kinds of hybrid mismatches.