OECD releases two discussion drafts on hybrid mismatch arrangements


The two draft reports released on 19 March 2014 by the OECD call for the introduction of both domestic rules and amendments to the OECD Model Tax Convention to neutralize the effect of hybrid mismatch arrangements. The recommendations of the OECD on hybrid mismatch arrangements result from Action 2 of the Action Plan on Base Erosion and Profit Shifting (BEPS Action Plan).

If the recommendations are widely adopted they are likely to have a significant impact on multinational enterprises (MNEs).

Click here to read more (PwC Tax Insights).

Click here to read the OECD discussion drafts.

PwC Webcast

Please also join our webcast on 27 March where PwC will look at the newly released discussion drafts and explore what this will mean for international business.

This one hour webcast will provide:

  • An overview of the OECD discussion draft on hybrid mismatch arrangements
  • A summary of the proposed recommendations to domestic tax laws and the OECD model treaty
  • An outline of the various classes of commonly adopted arrangements that are seen as giving rise to tax outcomes that the OECD considers undesirable
  • Ways to coordinate the recommendations with those of other BEPS working groups, particularly Treaty Abuse, Debt Leverage and CFCs


  • Adam Katz, Partner, PwC US, Moderator
  • Calum Dewar, Partner, PwC US
  • Wybe Mebius, Partner, PwC Netherlands

To register for this event, please visit the following link.

Once you register, you will receive a confirmation email with a link and access instructions for joining the webcast.

Who should attend? 

Companies with a global footprint who are concerned about the impact of hybrid mismatch arrangements on their business.

CPE details:

This webcast will be delivered in a group live – internet based format. This webcast will qualify for up to one CPE credit(s) in Taxes. Participants will need to log on from their individual computers to receive CPE credit(s). There is no charge to participate in this webcast; no prerequisites or advanced preparation are required.

Presentation slides / playback:

A recording of the webcast and the presentation slides will be available for playback and download after the live event, please check our website again.