Clifford Chance

BEPS Action 2 – Hybrids: OECD final proposals and their potentially wide impact on cross-border dealings

5 October 2015

As part of the OECD's Base Erosion and Profit Shifting ("BEPS") project, final proposals have been published to address cross-border hybrid arrangements that give rise to tax outcomes that are not consistent between jurisdictions.

Following on from our September 2014 client briefing on the OECD's initial recommendations to address that tax "mismatch", we provide an update on the final proposals and look at their potential impact on cross-border business and where we head now on the taxation of hybrid arrangements.

 

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