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)
Over 330 senior tax officials from more than 110 jurisdictions and international organisations met in Paris on 26-28 March 2014 during the 3rd Annual Meeting of the Global Forum on Transfer Pricing.
Public comments are invited on discussion drafts that include the proposals produced with respect to Action 2 (Hybrid Mismatch Arrangements) of the BEPS Action Plan.
National tax laws have not kept pace with the globalisation of corporations and the digital economy, leaving gaps that can be exploited by multi-national corporations to artificially reduce their taxes.
While after-tax hedging is not, of itself, aggressive - being generally a straightforward risk management technique - the report recognises that it can also be used as a feature of aggressive tax planning (ATP) schemes. ATP schemes based on after-tax hedging pose a threat to countries’ revenue base.
Aggressive tax planning (ATP) schemes based on after-tax hedging pose a threat to countries’ revenue base. Empirical evidence suggests that hundreds of millions of USD are at stake, with a number of multi-billion transactions identified by countries.
English, Excel, 6,716kb
Dispositifs Hybrides: Questions de politique et de discipline fiscales
The OECD's work on Aggressive Tax Planning focuses on helping tax authorities to respond more quickly to tax risks, to identify trends and patterns already identified and experienced by some tax administrations, and to share experiences in dealing with them
Aggressive tax planning – untaxed income, multiple deductions and other forms of international tax arbitrage - is a growing concern for all governments.