Hybrid mismatch arrangement

Tax.

A hybrid mismatch arrangement is an arrangement:

• Intended to secure a tax advantage within a multinational group
• Resulting from a difference in tax treatment of the same financial instrument or entity between different jurisdictions.

Hybrid mismatch arrangements can arise both from hybrid financial instruments and from hybrid entities.

Following OECD and G20 initiatives in relation to tax base erosion and profit shifting, the UK introduced anti-hybrid tax rules, effective from 2017.

See also

• Base erosion and profit shifting
• Business in Europe: Framework for Income Taxation
• CbC reporting
• Corporation Tax
• Diverted profits tax
• Double taxation
• Fixed ratio method
• G20
• Hybrid
• Hybrid capital
• Hybrid entity
• Multinational corporation/company
• Organisation for Economic Co-operation and Development (OECD)
• Tax avoidance
• Transfer pricing
• Worldwide interest cap

Other resources

• OECD Action Plan on Base Erosion and Profit Shifting 2013
• Walk the line, The Treasurer, 2015