20 September 2016 New Zealand introduces proposals to address hybrid mismatch arrangements The New Zealand Government released a discussion document on September 6 that sets out a number of proposals for addressing hybrid mismatch arrangements involving the use of hybrid instruments or entities. The discussion document sets out the Government's intention to introduce almost all of the anti-hybrid recommendations from the Organisation for Economic Co-operation and Development's (OECD's) Action Plan on Base Erosion and Profit Shifting (BEPS). The proposals center on a series of linking rules that would deny deductions or demand inclusion of hybrid income, in order to avoid exploitation of hybrid mismatches across different jurisdictions. Document ID: 2016-1575 |
