17 March 2016

An overly ambitious approach to hybrids by the OECD (BNA)

James Tobin, a partner with Ernst & Young's International Tax Services group, recently authored an article published in BNA's Tax Management International Journal discussing the final OECD BEPS report on Action 2 — Neutralizing the Effects of Hybrid Mismatch Arrangements.

According to the article, the comprehensive report on hybrids bravely attempts to deal with all manner of potential mismatches that one could imagine. The author further notes that the recommendations for the most part require legislative action by each country and the intent is that countries all follow a consistent design to ensure achievement of the goal of eliminating the targeted hybrid mismatches.

The article, published in the February 12, 2016, edition of Tax Management International Journal, is attached below.

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ATTACHMENT

Document ID: 2016-0512