The OECD has released two discussion drafts on BEPS action item 2, which calls for development of model treaty provisions and recommendations regarding the design of domestic rules to neutralize the effects (double non-taxation, double deduction, and long term deferral) of hybrid mismatch arrangements.
Comments are requested by May 2014, Press Release; Discussion Draft on Treaty Issues; Discussion Draft on Recommendations for Domestic Laws; Analysis: EY, Deloitte
