Transcription of (Treaty Issues) - oecd.org
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(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.
Hybrid mismatch arrangements can be used to achieve unintended double nontaxation or long- term tax deferral by, for instance, creating - two deductions for one borrowing, generating deductions without corresponding income inclusions,
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