Exchange of information

Hybrid Mismatch Arrangements: Tax Policy and Compliance Issues


Press release | Table of contents | More information


Publication Date: 05/03/2012

Pages: 25


Aggressive Tax Planning is an increasing source of concern for many governments. This new OECD report describes the most common types of hybrid mismatch arrangements (i.e. arrangements exploiting differences in the tax treatment of instruments, entities or transfers between two or more countries) and the effects they aim to achieve. It summarises the tax policy issues raised by these arrangements and describes the policy options to address them, with a focus on domestic law rules which deny benefits in the case of hybrid mismatch arrangements and countries’ experiences regarding their application. The report concludes that the same concern that exists in relation to distortions caused by double taxation exists in relation to unintended double non- taxation and recommends a number of actions to be undertaken.


 Press Release


05/03/2012 - OECD recommends action on international tax loopholes


  Table of Contents



Chapter 1. Hybrid Mismatch Arrangements
Chapter 2. Policy Issues
Chapter 3. Policy Options
Chapter 4. Rules Specifically Addressing Hybrid Mismatch Arrangements
Chapter 5. Country Experience With The Application Of Rules Specifically Addressing Hybrid Mismatch Arrangements
Conclusions and Recommendations


 More information



For further information, please contact Achim Pross  ( or Raffaele Russo ( from the Centre for Tax Policy and Administration.


Related Documents


Addressing Tax Risks Involving Bank Losses

Building transparent tax compliance by banks

Study into the Role of Tax Intermediaries

Framework for a Voluntary Code of Conduct for Revenue Bodies and Banks

Fighting unintended double non-taxation

Aggressive Tax Planning