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Global companies with legal entities in different tax jurisdictions can achieve tax avoidance or evasion by using complex financial instruments that are hybrid in nature.
Global companies with legal entities in different tax jurisdictions can achieve tax avoidance or evasion by using complex financial instruments that are hybrid in nature. Hybrid financial instruments income payment may have ambiguous legal and taxation definitions, whether they are interest or dividend distribution for inter-company financing arrangements. The global companies may be able to minimise their consolidated tax expense and payment by taking the advantage of: a. Both the paying and receiving companies tax authorities exclude the transaction as neither deductible nor taxable. b. The paying company's tax authority allowing the payment to be tax deductible at 30%, and the income-receiving company's tax authority tax it as income at 35%. c. The paying company's tax authority disallowing the payment to be tax deductible, and the income-receiving company's tax authority tax it as an income. d. The paying company's tax authority allowing the payment to be tax deductible at 30%, and the income-receiving company's tax authority exempt it from being taxable, or taxable at a lower rate than 30%. e. The paying company's tax authority allowing the payment to be tax deductible at 30%, and the income-receiving company's tax authority tax it as income at 30%
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