Law Commons^™

Reactions To Hybrid Mismatch Arrangements And Strategy Suggestions For Korea, Aju Nam

Maurer Theses and Dissertations

In recent years, the Organisation for Economic Co-operation and Development (OECD)’s Base Erosion and Profit Shifting (BEPS) project has been one of the biggest issues in international taxation. The OECD refers to BEPS as “tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations.” In 2014, the OECD released BEPS Action 2 as responds on Hybrid Mismatch Arrangements (“HMA”s), which are arrangements exploiting differences in the tax treatment of instruments, entities or transfers between two or more countries. Two of the major factors of HMAs are hybrid entities and hybrid …