Executive summary
On 29 April 2022, the Canadian Government released draft legislative proposals and accompanying explanatory notes (referred to herein as the hybrid mismatch rules) to address certain hybrid mismatch arrangements.
As per the explanatory notes, these rules are intended to implement the recommendations in, and be generally consistent with, the Final Report under Action 2 of the Organisation for Economic Co-operation and Development/G20’s Base Erosion and Profit Shifting (BEPS) Proje…