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Neutralizing effects of hybrid mismatch arrangementsmismatches will be for all jurisdictions to introduce rules recommendedin this Report.” 99 The OECD Public Discussion Draft on BEPS Action2 — Domestic Issues specifically recommended that in certain circumstancesintermediate States treat hybrid entities as tax residents, especiallywhere that is consistent with the characterization of the entity inthe investor State. 100 The OECD Action 2 — 2014 Deliverable no longermakes any specific recommendations with respect to intermediate States.4. Other steps that may be takenThe recommendations in the OECD Action 2 — 2014 Deliverableand OECD Public Discussion Draft on BEPS Action 2 — DomesticIssues are long, disjointed, complex and difficult to follow, and thisdiscussion has sought to avoid some of their more complex parts. 101The OECD documents contain a clear and appropriate set of designprinciples. 102 However, the recommendations appear to promote fewof these. The recommendations are not “comprehensive” and wouldnot “minimise the disruption to existing domestic law,” “be clear andtransparent in their operation,” “be workable for taxpayers and keepcompliance costs to a minimum” or be “easy for tax authorities toadminister.” 103 Further, as noted in section 3.1 above, in the face of99OECD Action 2 — 2014 Deliverable, supra note 2, paragraph 108;Nathan Boidman and Michael Kandev, “BEPS Action Plan on Hybrid Mismatches:A Canadian Perspective,” supra note 1, 1244, refer to this as “plainlyutopic.”100OECD Public Discussion Draft on BEPS Action 2 — Domestic Issues,supra note 2, 61, paragraph (b).101Such as the examples in OECD Public Discussion Draft on BEPSAction 2 — Domestic Issues, supra note 2, paragraphs 237-240, some of whichinvolve situations where two countries disagree on the identity of both thepayer and the recipient of a payment.102OECD Action 2 — 2014 Deliverable, supra note 2, 64-65, and OECDPublic Discussion Draft on BEPS Action 2 — Domestic Issues, supra note 2,paragraph 27.103See Amanda Athanasiou, “Hybrid Mismatch Proposals: PracticalProblems Remain,” (2014) Vol. 74, Tax Notes International, 1083, who notesthat “foremost among stakeholder concerns during this process has been thefear that administration of the rules and coordination among jurisdictions,239