OECD has publicised a new report on Hybrid Mismatch Arrangements.
The report describes the most common types of hybrid mismatch arrangements that exploit national differences in the tax treatment of instruments, entities or transfers to deduct the same expense in several different countries, to make income “disappear” between countries or to artificially generate several tax credits for the same foreign tax.
The report describes the policy options to address the issues, with a focus on domestic law rules which deny benefits in the case of hybrid mismatch arrangements and countries’ experiences regarding their application. The report concludes that the same concern that exists in relation to distortions caused by double taxation exists in relation to unintended double non- taxation and recommends a number of actions to be undertaken.
Read the full report here.