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As Managing Partner at Accountants on Mission for over 13 years, Dr. Phiri has driven strategic direction in accounting, tax advisory, corporate governance, and risk management, with a focus on the mining industry. His role includes the implementation of IFRS standards, business research, business restructuring, M&A and corporate governance. He is an ACCA Approved Employer member thus offering articles to ACCA trainee accountants. With expertise in international tax, including hybrid mismatch arrangements and the OECD BEPS, OECD MTC, he serves multinational enterprises in mining, manufacturing, and services industries. Dr. Phiri specialises in resolving complex tax disputes with the South African Revenue Services in excess of R40m and advising on tax optimisation strategies. His work reflects a commitment to fostering compliance, ethics, and sustainable growth for organisations. In terms of academic research Dr. Phiri is a postdoctoral researcher. His research on the Executive Doctor of Business Administration (EDBA) thesis with a specialisation in international tax was based on “International Tax: Hybrid Mismatch Arrangements and Shortcomings of the OECD BEPS Action 2 Final Report 2015” focusing on four objectives, to find out if the OECD BEPS Action 2 recommendations have shortcomings in its effort to neutralise the effects of hybrid mismatch arrangements. The study was conducted within MNEs in South Africa and incorporated the positivism research philosophy whereby science is used to philosophise existing theories and test hypothesis thereby incorporating cross sectional regression analysis. Probability sampling was used to collect data. The study performed tests including the Breusch-Pagan (Chi-Square) for heteroskedasticity, the Durbin Watson, for autocorrelation and the F-tests. Findings were contrary to the OECD BEPS Action 2 recommendations, to paraphrase it, the OECD has shortcomings in neutralising the effects of hybrid mismatch arrangements. Limitations of the study were mainly costs and time constraints. Future studies can be conducted within MNEs that are trading on any of the world stock exchanges and can be conducted by incorporating a mixed-method and incorporate the probability and non-probability sampling techniques (triangulation). The study recommended that the OECD collaborates with IFAC and involves professional postdoctoral researchers in the field to review the project. The study has over 90 citations, 243 pages and was defended on 16 September 2025 with an 85% mark (distinction).

Product Specifications

Format: paperback
ASIN: B0GP2626BT
Category: Books > Subjects > Business, Finance & Law > Professional Finance > Taxation > International
Domain: Amazon UK
Release Date: 16 February 2026
Listed Since: 18 February 2026

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International Tax: Hybrid Mismatch Arrangements and Shortcomings of the OECD BEPS Action 2 Final Report 2015

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New to our records — first sighting 17 days ago. We'll learn its rhythm.

International Tax: Hybrid Mismatch Arrangements and Shortcomings of the OECD BEPS Action 2 Final Report 2015

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