OECD/G20 Base Erosion and Profit Shifting Project

2313-2612 (online)
2313-2604 (print)
Hide / Show Abstract

Addressing base erosion and profit shifting is a key priority of governments around the globe. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. Beyond securing revenues by realigning taxation with economic activities and value creation, the OECD/G20 BEPS Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. In 2016, the OECD and G20 established an Inclusive Framework on BEPS to allow interested countries and jurisdictions to work with OECD and G20 members to develop standards on BEPS related issues and reviewing and monitoring the implementation of the whole BEPS Package. Over 100 countries and jurisdictions have joined the Inclusive Framework.


Also available in French, German, Spanish
Neutralising the Effects of Hybrid Mismatch Arrangements

Neutralising the Effects of Hybrid Mismatch Arrangements You or your institution have access to this content

Click to Access: 
  • PDF
  • http://www.keepeek.com/Digital-Asset-Management/oecd/taxation/neutralising-the-effects-of-hybrid-mismatch-arrangements_9789264218819-en
  • READ
16 Sep 2014
9789264218819 (PDF) ;9789264218796(print)

Hide / Show Abstract

This report sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements. Once translated into domestic law, the recommendations in Part 1 of the report will neutralise the effect of cross-border hybrid mismatch arrangements that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part 1 of the report will be supplemented by a commentary, which will explain the recommended rules and illustrate their application with practical examples. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.

loader image

Table of Contents

Executive summary
Part I. Recommendations for the design of domestic rules
Chapter 1. Definition of hybrid mismatch arrangement
Chapter 2. Arrangements that produce D/NI outcomes
Chapter 3. Arrangements that produce DD outcomes
Chapter 4. Arrangements that produce indirect D/NI outcomes
Chapter 5. Implementation
Chapter 6. Definitions in relation to scope
Chapter 7. Key terms
Part II. Recommendation on treaty issues
Chapter 8. Dual–resident entities
Chapter 9. Treaty provision on transparent entities
Chapter 10. Interaction between Part I and tax treaties

Visit the OECD web site