Hybrid Mismatch Arrangements : Interest Deductions and Other Financial Payments

Book excerpt: The OECD base erosion and profit shifting (BEPS) 15-point Action Plan contains two action points addressing aspects of financing in the broadest sense. Action 2 is intended to neutralize the effects of hybrid mismatch arrangements, and Action 4 seeks to limit base erosion involving interest deductions and other financial payments. These action points essentially concern issues regarding the allocation of taxation associated with internal group financing arrangements. However, they also address structured financing. This article examines both action points.