Preventing Tax arbitrage via Hybrid Mismatch- es: BEPS Action 2 and Developing Countries

Content Provider	Semantic Scholar
Author	Kuźniacki, Błażej Turina, Alessandro Dubut, Thomas Mazz, Addy Quiñones, Natalia Schoueri, Luís Eduardo West, Craig Pistone, Pasquale Zimmer, Frederik
Copyright Year	2017
Abstract	The Organization for Economic Cooperation and Development (OECD) under Base Erosion and Profit Shifting (BEPS) Action 2 indicated that tax arbitrage via hybrid mismatch arrangements “result in a substantial erosion of the taxable bases of the countries concerned” and “have an overall negative impact on competition, efficiency, transparency and fairness.” The relevant action allowing for neutralising the effects of hybrid mismatch arrangements is therefore needed and justified. To achieve that purpose, the OECD developed different anti-hybrid rules under BEPS Action 2. In that regard, however, one may ask whether addressing tax arbitrage via hybrid mismatches as proposed by the OECD is of interest and relevance for developing countries. This paper aims to map that unexplored research area by means of a comparative analysis in four developing countries – Uruguay, Colombia, Brazil, and South Africa.
File Format	PDF HTM / HTML
Alternate Webpage(s)	http://epub.wu.ac.at/5502/1/SSRN-id2941617.pdf
Language	English
Access Restriction	Open
Content Type	Text
Resource Type	Article