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Part 35C-00-01 - Part 35C Hybrid Mismatches - Revenue
www.revenue.ieThe OECD BEPS Action 2 report clearly sets out in para. 13 that “while cross-border mismatches arise in other contexts…the only types of mismatches targeted by this report are those that rely on a hybrid element to produce such outcomes.” As such, the purpose of the anti-hybrid rules is to address mismatches that arise due to