Hybrid benefits denied

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Hybrid benefits denied

August 31 2000

The US Treasury has published its final regulations denying US treaty benefits to payments made through so-called hybrid entities. The regulations’ limited scope means they only deny treaty benefits that might otherwise be available. By Kim Blanchard of Torys, New York

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

FeatureSponsoredITR MagazineSeptember 2000
more across site & shared bottom lb ros

More from across our site

Direct Tax
Internal Revenue Serice Sign
This week in tax: IRS has lost 11% of its workforce, report finds
The cuts disproportionately affected staff in certain positions, the report also found; in other news, MHA announced the €24 million acquisition of Baker Tilly South East Europe
Sam Sholli, May 09 2025
Transfer Pricing
india.jpg
India sets APA resolution targets in 2025/26 action plan
The plan aims to improve the efficiency, transparency, and effectiveness of direct tax administration in India
Sam Sholli, May 08 2025
Direct Tax
Part of Eton College viewed from playing fields
This month in indirect tax: UK denies private school VAT breaches human rights law
Meanwhile, South Africa’s finance minister has accepted a court decision on suspending a VAT increase and US President Donald Trump mulls a 100% tariff on foreign films
Sam Sholli, May 07 2025
Direct Tax
Jaime Carey, president of the International Bar Association
IBA president: OECD’s two-pillar solution is ‘crucial’
Jaime Carey speaks about the benefits of his tax background, DEI values, the use of AI for a smarter legal practice, and other priorities that will define his presidency
Noemi Distefano, May 06 2025
Direct Tax
Oslo, Norway - 24 September 2022: PricewaterhouseCoopers or PWC
PwC to lay off ‘about 1,500 employees’ in US: report
Historically low levels of attrition over consecutive years made a ‘difficult decision’ necessary, PwC has reportedly said
Sam Sholli, May 06 2025
Direct Tax
kelly mgbor resized.jpg
WTS aims to capture PwC’s former francophone African footprint
WTS Global is also vetting new potential member firms in Algeria, Cote D’Ivoire and Benin, Kelly Mgbor tells ITR in an exclusive interview
Tom Baker, May 05 2025
Direct Tax
EU flag large
This week in tax: EU mulls pillar two revisions to placate US
The scope of qualifying pillar two tax credits could reportedly be broadened; in other news, hundreds of IRS appeals staff are to resign
Tom Baker, May 02 2025
Transfer Pricing
Europe map technology
Bilateral APAs have their moment
For many taxpayers, the prospect of long-term certainty that a bilateral APA offers can override concerns about time, cost and confidentiality
Ralph Cunningham, May 01 2025
Direct Tax
scott levine resized.jpg
Baker McKenzie picks up former US Treasury deputy Scott Levine
Levine, who served under the Joe Biden administration, led the US’s negotiations on the OECD’s two-pillar solution
Tom Baker, April 30 2025
Direct Tax
Legal Benchmarking unstacked@4x.png
Legal Benchmarking Group acquired by Triple Private Equity
The deal to acquire ITR's parent company is expected to complete by the end of May 2025
Tom Baker, April 29 2025
Gift this article