Addressing Hybrid Mismatch Arrangements: A Government Discussion Document

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Inland Revenue Department

As a general comment, NZBA supports the ongoing work of the OECD to address valid concerns over base erosion and profit shifting (BEPS). As is highlighted by the OECD, implementation of the OECD’s BEPS recommendations should be co-ordinated on a multilateral approach. In the case of the anti-hybrid mismatch proposals, it will be important that New Zealand and Australia are aligned. In addition, given the complexity of the anti-hybrid mismatch proposals, it will be critical that any rules are clear and certain, particularly from a bank regulatory capital perspective to ensure certainty for investors, banks and the New Zealand banking system (including prudential regulators).

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