OECD releases two discussion drafts on hybrid mismatch arrangements

Tax Policy Bulletin ()
The two draft reports released on March 19, 2014 by the OECD call for the introduction of both domestic rules and amendments to the OECD Model Tax Convention to neutralize the effect of hybrid mismatch arrangements. The recommendations of the OECD on hybrid mismatch arrangements result from Action 2 of the Action Plan on Base Erosion and Profit Shifting (BEPS Action Plan).
If the recommendations are widely adopted they are likely to have a significant impact on multinational enterprises (MNEs).