BEPS 2015: hybrid mismatches face clampdown in OECD BEPS plan

The OECD BEPS package of anti-avoidance tax measures includes final guidance and a robust framework to counter abuse of hybrid mismatches, highlighted in action 2, in an attempt to deal with distortion of competition created by a tax environment which offers multinational companies significant cross-border tax advantages

While the majority of the work on hybrid mismatches was completed earlier this year by OECD detailed guidance is now available and already a number of countries including the UK, are planning to adopt counter hybrid rules although adoption is optional. Australia has also announced that it will introduce legislation.

‘There was a consensus that we needed to do something about mismatch arrangements. On hybrid mismatches, those countries interested in protecting themselves can do so, but without damaging themselves,’ said Pascal Saint Amans. director for the Centre of Tax Policy & Administration at the OECD.

‘The changes to hybrid mismatches were already agreed last year and have provided guidelines for countries – some countries have already passed legislation.’

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