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Peter A. Harrisnot clear, at least from a conceptual perspective. 63 Inevitably, any form ofhybrid mismatch arrangement can arise in the context of three or morecountries. Issues raised through the use of an intermediary State seemto be little more than the usual issues pertaining to treaty shopping andtax havens. The OECD Action 2 — 2014 Deliverable and OECD PublicDiscussion Draft on BEPS Action 2 — Domestic Issues incorporate littleexplanation of the relationship between hybrid mismatch arrangementsand these issues of treaty shopping and the use of tax havens. 64A subsequent example (figure 18) in the OECD Public DiscussionDraft on BEPS Action 2 — Domestic Issues demonstrates two furtherpoints: that a hybrid mismatch can be “imported” into a recipient Statethrough an intermediate State and that a PE may be used in the intermediateState. 65 The OECD Public Discussion Draft on BEPS Action2 — Domestic Issues contains part VII entitled “Further TechnicalDiscussion and Examples.” This part is not clearly linked with, andthe examples used are not categorized by reference to, the prior parts.The OECD Action 2 — 2014 Deliverable largely ignores it. Like the discussionof imported mismatches in part VI, using a PE in a third Stateraises few issues in addition to those that generally arise when locatinga PE in a low-tax jurisdiction, especially where the residence Stateprovides foreign tax relief in the form of an exemption. 6663OECD Public Discussion Draft on BEPS Action 2 — Domestic Issues,supra note 2, paragraph 216, attempts to explain the connection. Paragraph217 explains the “difference between reverse hybrids and imported mismatcharrangements … as a difference between direct and indirect mismatches.”This seems to be a virtual non-distinction and to say little more than thatthe latter involves a third country and the former need not. The same couldbe said with respect to other (non-reverse) types of direct hybrid mismatcharrangements. This explanation is not repeated in the OECD Action 2 — 2014Deliverable, but see paragraph 88 therein, at 47.64OECD Public Discussion Draft on BEPS Action 2 — Domestic Issues,supra note 2, paragraph 209, notes that an intermediate jurisdiction willhave “little incentive” to introduce rules to neutralize hybrid mismatcharrangements.65Ibid., supra note 2, 72.66For example, see Peter A. Harris and David Oliver, International CommercialTax, supra note 29, 353 and 389-91.224