A Study Ofanti-avoidance On Hybrid Mismatch Arrangment: Based On Scheme A, B, C, D’s Tax Arrangements

Mixed mismatch is one of the multinational corporation’s tax planning activities, the tax body’s purpose is to achieve double taxation or long-term deferred tax through different tax treatments for an entity. Multinational firms taking advantage of the loophole of different tax jurisdictions or tax treatments in tax avoidance is a product of the global "tax competition", which benefits the invested regions’ economic development. But more important, it highlights the lagged development of the current tax system and imperfection.The OECD report "Neutralising the Effects of Hybrid Mismatch Arrangements" has profoundly revealed many mixing mismatches are caused by mixed financial instruments or mixture payments, it calls on all sides to modify the domestic laws and improve the tax treaty model to deal with the mixed mismatches.By each tax jurisdiction’s establishing linkage mechanism, the mismatch results of deduction from one party and not included in the income in another party can be solved effectively.China’s current policy measures to cope with mixed mismatch arrangement problems are still not perfect, while the current international organization’s suggestions for mixed mismatch arrangement and some country’s practical experience are of great significance for us. As the abroad practice and suggestions may not entirely suit us, especially some tax arrangements have not happened, if we blindly copy foreign experience it may cause more harm than good to the economic development.This article basing on international experience and combining the reality of China’s economic development puts forward concrete suggestions.In the structure of the article, first of all, it introduces the research background and significance; Secondly, it explains how mismatch arrangements erode our country’s tax base erosion through A, B, C, D company’ tax arrangements activities; Then, on the basis of understanding the OECD’S main suggestions and some counties’ practical experience, it realizes our country’s shortage to cope with; Finally, it gives some suggestions on domestic law, the tax treaty as well as the international tax information exchanging to respond to mismatch arrangements;...