Public comments are invited on a discussion draft which deals with action 12 (Mandatory Disclosure Rules) of the BEPS Action Plan.
A public consultation on BEPS Action Item 4 (Interest deductions and other financial payments) was held in Paris at the OECD Conference Centre on 17 February 2015.
On 18 December 2014, interested parties were invited to comment on the discussion draft on Action 4 (Interest Deductions and other Financial Payments) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the comments received.
Public comments are invited on a discussion draft which deals with action 4 (Interest deductions and other financial payments) of the BEPS Action Plan
Engagement of developing countries in the international tax agenda, including on BEPS, is imperative, in particular to ensure they receive appropriate support to address the specific implementation challenges they face. The input received from developing countries has been fed directly into the development of the BEPS Action Plan.
The OECD Committee on Fiscal Affairs (CFA), bringing together 44 countries on an equal footing (all OECD members, OECD accession countries, and G20 countries), has adopted a final set of deliverables described in the Action Plan.
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.
English, PDF, 37kb
Revised draft agenda for the public consultation on Action Item 2
English, PDF, 13,441kb
Comments on Action item 2 - Hybrid Mismatch Arrangements
OECD publishes comments received on Action 2 discussions drafts (Neutralise the Effects of Hybrid Mismatch Arrangements)