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Abstract

Hybrid entities give rise to international tax problems and opportunities. Different countries tax systems treat hybrid entities in fundamentally different ways, allocating income to different parties. The tax consequences of this divergence of approach result in complex and unintended outcomes. Referring to the OECD Report on the taxation of Partnerships, this article looks at whether the treatment of trans-Tasman limited Partnerships under the Australian and New Zealand Convention results in double taxation or double non-taxation. It concludes that hybrid entity double taxation is, mostly, resolved through the operation of the Convention.

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