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Peter A. Harrisother instances of “double taxation of the same economic income” notaddressed by tax treaties, 104 it is not clear why the recommendationsmust necessarily “avoid double taxation through rule co-ordination.” 105The critical thing is to ensure sufficient taxation. Failure to meet thedesign principles may stem from the OECD attempting to be moretargeted and precise than is necessary for this limited purpose. 106The OECD recommendations will create interface issues withother domestic rules. For example, the OECD suggests that the hybridmismatch rules should be applied “after” general domestic tax baserules “but before the application of any general non-transaction specificlimitation such as a thin capitalisation rule.” 107 These “non-transactionspecific” rules may be more difficult to identify than suggested.Further, rules like these that affect a tax base can play havoc with otherrules that apply by reference to the tax base, such as earnings strippingrules, quarantining rules and even rules for limiting the deductibilityof charitable donations. In addition, the OECD Public DiscussionDraft on BEPS Action 2 — Domestic Issues notes the need for orderaswell as with other base erosion and profit-shifting initiatives and domesticlaw, will be prohibitively difficult, leading to double taxation, competitiveinequities, inefficiencies, and impossible compliance burdens.” See alsoMichael L. Schler, “BEPS Action 2: Ending Mismatches on Hybrid Instruments,”(Part 2), supra note 68, 581.104OECD Public Discussion Draft on BEPS Action 2 — Domestic Issues,supra note 2, paragraph 33.105OECD Action 2 — 2014 Deliverable, supra note 2, 64, Recommendation9, paragraph 1 (d); and OECD Public Discussion Draft on BEPS Action2 — Domestic Issues, supra note 2, paragraph 27 (d). Double taxation is aquestion of degree, not absolutes. Investors are likely to be deterred less bytwo light impositions of tax that are reasonably predictable and certain, thanone high level of tax with substantial degrees of uncertainty.106Hugh J. Ault, “Some Reflections on the OECD and the Sources ofInternational Tax Principles,” supra note 3, 1199, doubts that “the rules dealingwith the BEPS issues can be structured so accurately that they hit onlythe desired targets and there will inevitably be situations when undesirabledouble taxation could arise.”107OECD Public Discussion Draft on BEPS Action 2 — Domestic Issues,supra note 2, paragraph 241. Not repeated in the OECD Action 2 — 2014Deliverable.240