On May 1, 2014, TEI submitted comments to the OECD regarding its Public Discussion Drafts on BEPS Action 2: Neutralise the Effects of Hybrid Mismatch Arrangements (Recommendations for Domestic Laws and Treaty Issues). TEI’s comments focused on the need for the OECD to specifically delineate the instruments and transactions that would be subject to the proposed, the proposed rules intended effect, and to coordinate the rules’ implementation across jurisdictions to prevent double-taxation from arising.
TEI’s comments were prepared under the aegis of TEI’s European Direct Tax Committee, whose chair is Nick Hasenoehrl of Herbalife. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s comments.
Committee