OECD recommends action on international tax loopholes
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Aggressive Tax Planning (ATP) Steering Group of OECD releases report on 'hybrid mismatch arrangements'; India one of the participants to the Group; OECD recommends specific and targeted rules in domestic tax law
OECD has released a new report on "Hybrid Mismatch Arrangements: Tax Policy and Compliance Issues" dealing with hybrid mismatch arrangements which exploit differences in the tax treatment of instruments, entities or transfers between two or more countries. OECD in its Press Release stated that "Anecdotal evidence shows that billions of dollars in tax revenues are at stake. New Zealand settled cases involving 4 banks for a combined sum exceeding NZD 2.2 billion. Italy recently settled a dozen cases involving hybrids for an amount of approximately EUR 1.5 billion. In the United States, the amount of tax evaded in 11 foreign tax credit generator transactions has been estimated at USD 3.5 billion."
The report summarises the tax policy issues raised by these arrangements and describes the policy options to address them, with a focus on domestic law rules which deny benefits in the case of hybrid mismatch arrangements and countries’ experiences regarding their application. The report ends with conclusions and recommendations for tax administrations and tax policy makers.
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