(Treaty Issues) - oecd.org

public Discussion draft BEPS ACTION 2: NEUTRALISE THE EFFECTS OF HYBRID MISMATCH ARRANGEMENTS (Treaty Issues) 19 March 2014 2 May 2014 2 Comments on this note should be sent electronically (in Word format) by email to before on 2 May 2014 at the latest. It is the policy of the OECD to publish all responses (including the names of the responders) on the OECD website. This document does not necessarily reflect consensus views of either the Committee of Fiscal Affairs or of WP1 regarding the issues it addresses. Rather it reflects preliminary consideration of the issues since the publication of the Action Plan and seeks to identify issues for public comment. It is considered that stakeholder comments are essential to advancing this work. 3 TABLE OF CONTENTS Introduction .. 4 1. Ensuring that dual resident entities are not used to obtain the benefits of treaties unduly .. 5 2. Ensuring that transparent entities are not used to obtain the benefits of treaties unduly.

Public Discussion Draft BEPS ACTION 2: NEUTRALISE THE EFFECTS OF HYBRID MISMATCH ARRANGEMENTS (Treaty Issues) 19 March 2014 – 2 May 2014

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