BEPS Action 2 and the Non-Discrimination Rule Under the GATS - Intertax View BEPS Action 2 and the Non-Discrimination Rule Under the GATS by - Intertax BEPS Action 2 and the Non-Discrimination Rule Under the GATS 49 4

This article is intended to analyse whether Recommendations 1.1. and 1.2. of the Final Report of Base Erosion and Profit Shifting Action Plan 2 – which makes a number of proposals to design domestic tax rules in order to tackle mismatch arrangements caused by the use of hybrid financial instruments – would harm the non-discrimination rules of the General Agreement on Trade in Service.

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