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of <h1>Action Plan 2 Targets Hybrid Mismatch Arrangements to Prevent Tax Abuse and Ensure Proper Taxation Under OECD Guidelines</h1> Action Plan 2 addresses hybrid mismatch arrangements, which exploit differences in tax treatment across jurisdictions to achieve unintended tax benefits like double non-taxation or tax deferral. It proposes model treaty provisions and domestic rules to neutralize these effects, including denying deductions for payments not included in the recipient's income or deductible elsewhere. The plan suggests changes to the OECD Model Tax Convention and domestic laws to prevent abuse of treaties and ensure proper taxation. It also introduces anti-hybrid rules and addresses branch mismatches, recommending targeted measures for banks and insurance companies to mitigate base erosion and profit shifting.
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