Optymalizacja podatkowa z wykorzystaniem hybrydyzacji

Małgorzata Hybka

Abstract

The main aim of this article is to overview tax optimization schemes involving the application of hybrid mismatch arrangements. These arrangements exploit differences in tax treatment of certain instruments, transfers or entities between countries. Hybrid mismatch arrangements are not often the subject of analysis in Polish economic literature, with an exception of hybrid instruments which are applied quite often for tax optimization purposes in Poland. The article also indicates negative consequences of the use of hybrid mismatch arrangements and anti-avoidance provisions implemented by countries to prevent these consequences.