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Neutralizing effects of hybrid mismatch arrangementsis established in a different jurisdiction.” 59 While that may be, it failsto highlight the significance of a mismatch structure involving receiptof a payment by a hybrid entity.As with payments made by hybrid entities, the significance ofa mismatch with respect to receipt of a payment by a hybrid entity isthat it can be achieved in a bilateral setting. After all, the tax benefitsof the structure in figure 11 of OECD Public Discussion Draft on BEPSAction 2 — Domestic Issues can also be achieved by using a non-hybridentity established in a favourable third country. 60 It may be arguedthat the State of the payer could unwittingly reduce withholding tax bypresuming a tax treaty with the intermediate State applies. But this canbe countered with what seems to be the position of the OECD itself. Itseems that a hybrid in such an intermediate State is not “liable to tax”there and so is not a “resident” of the intermediate State for tax treatypurposes and the treaty does not apply. 61 The risk with the extensionof OECD is that tax administrators may think that mismatches arisingwith respect to receipt of a payment by a hybrid entity arise only intriangular cases.This causes the OECD Action 2 — 2014 Deliverable and OECDPublic Discussion Draft on BEPS Action 2 — Domestic Issues to turnimmediately to what they term “imported mismatches,” which are“hybrid structures created under the laws of two jurisdictions where theeffects of the hybrid mismatch are imported into a third jurisdiction.” 62The connection between “reverse hybrids” and “imported mismatches” is59OECD Public Discussion Draft on BEPS Action 2 — Domestic Issues,supra note 2, paragraph 201. This comment is not repeated in the OECDAction 2 — 2014 Deliverable.60Peter A. Harris and David Oliver, International Commercial Tax, supranote 29, 388-89.61Paragraph 8.8 of the Commentary on Article 4 of the OECD ModelConvention, although this comment is made in the context of hybrid partnerships.See also Peter A. Harris and David Oliver, International CommercialTax, supra note 29, 63 and 348.62OECD Public Discussion Draft on BEPS Action 2 — Domestic Issues,supra note 2, paragraph 206, and see the slightly different description inOECD Action 2 — 2014 Deliverable, supra note 2, 61.223