Are We There Yet? International Implementation of Hybrid Mismatch Rules

This article provides an overview of hybrid mismatch recommendations under Action 2 of the OECD/G20 Base Erosion and Profit Shifting Project and the EU Anti-Tax Avoidance Directive (2016/1164 and 2017/952), a snapshot of their international implementation to date and a preliminary comparison of hybrid mismatch legislation in specific countries.