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 has introduced anti-hybrid tax rules, effective from 2017.

See also

• Base erosion and profit shifting
• CbC reporting
• Common Consolidated Corporate Tax Base
• Corporation Tax
• Diverted profits tax
• Fixed-ratio method
• G20
• Hybrid
• Multinational corporation/company
• OECD
• Worldwide interest cap
• Tax avoidance
• Transfer pricing
• Double taxation

Other links

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