Preventing Tax arbitrage via Hybrid Mismatches: BEPS Action 2 and Developing Countries

Blazej Kuzniacki, Alessandro Turina, Thomas Dubut, Addy Mazz, Natalia Quiñones, Luís Eduardo Schoueri, Craig West, Pasquale Pistone, Frederik Zimmer

Publication: Working/Discussion PaperWU Working Paper

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The Organization for Economic Cooperation and Development (OECD) under Base Erosion and
Profit Shifting (BEPS) Action 2 indicated that tax arbitrage via hybrid mismatch arrangements "result in a
substantial erosion of the taxable bases of the countries concerned" and "have an overall negative impact on
competition, efficiency, transparency and fairness." The relevant action allowing for neutralising the effects of
hybrid mismatch arrangements is therefore needed and justified. To achieve that purpose, the OECD
developed different anti-hybrid rules under BEPS Action 2. In that regard, however, one may ask whether
addressing tax arbitrage via hybrid mismatches as proposed by the OECD is of interest and relevance for
developing countries. This paper aims to map that unexplored research area by means of a comparative
analysis in four developing countries - Uruguay, Colombia, Brazil, and South Africa.
Original languageEnglish
Place of PublicationVienna
PublisherWU Vienna University of Economics and Business
Publication statusPublished - 2017

Publication series

NameWU International Taxation Research Paper Series

WU Working Paper Series

  • WU International Taxation Research Paper Series

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