Transfery i finansowe instrumenty hybrydowe − komponenty agresywnej strategii podatkowej?
Hybrid transfers and financial instruments – aggressive tax strategy components?

Summary/Abstract: According to the OECD report released in 2012 aggressive tax planning strategies of multinational corporations involve the application of hybrid mismach arrangements. The main aim of this article is to demonstrate how hybrid transfers and hybrid financial instruments are used for tax optimization purposes. The first part of this article defines aggressive tax strategy and the second one ilustrates the usage of the collateralised loan repo for the above-mentioned purposes. Hybrid finanncial instruments and their application are reviewed in the last section.

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