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hmm...well voldemort can´t do much to orochi due to the massive ap diffrence (the killing curse might work but as far as im aware thats about it.), but orochi can´t kill voldemort due to his type 8 immortality and low godly regen, but during prep he could probably find and destroy the horcruxes, negating the type 8 immortality, then he could simply oneshot voldemort due to having mountain level+ ap and voldemort only having city block level durability and that would be that.
Even Dumbledoor who had several years prep time of Voldemort could not destroy all the horcruxes and in fact was dying as a result of destroying the ring, so I do not see how Orochimaru would do any better. Plus if speed is equalized that gives voldemort a better opprtunity to hit orochimaru. The Imperius Curse is basically just mind control and the cruciatous curse could immobilize orochimaru.
You are also giving Voldemort two years prep time and he was smart enough to overthrow the ministry of magic in only one year. Not a stomp but I think Voldemort takes the comfortable advantage because he has a several one shot abilties and I do not see how his immortality will be stripped away.
Doesn't Orochimaru have access to, through Ryuchi Cave, a vast number of snakes, many of whom likely have special venom, like Garaga's petrifying spit venom? He could easily find a basilisk himself, if an equivalent doesn't already exist within Ryuchi Cave, and put a Summoning Contract on it. And then he has mobile Horcrux destroyer. Orochimaru is definitely intelligent enough to read through Voldemort's movements; and honestly, the way the Ministry of Magic is written, they're hilariously incompetent at their jobs.
I'd argue Orochimaru is a good deal smarter than either Voldemort or Dumbledore, honestly. Orochimaru was not only a master with manipulating chakra and jutsu on a level equalling or possibly surpassing Dumbledore and Voldemort's genius with magic, but he was well-versed in science, which is something neither Dumbledore nor Voldemort seem to give any weight to. Given the fact that the Unforgivable Curses can be blocked with simple inanimate objects, something that Orochimaru would no doubt be aware. The Rashoman gates, Earth Release: Mud Wall, Hiding Like a Mole/Hiding in Surfaces technique to phase through the ground, shedding his skin to misdirect Voldemort's spells when the real one has escaped underground...
I really don't see why anyone thinks Orochimaru doesn't take this, adding in his enormous AP advantage.
Pretty sure Oro can just one shot Tom's fodder body and be done with it since getting a new body will take too long. The Low Godly isn't combat applicable from what I recall and dodging the shiny green beam or using clones is pretty in character. Plus flexing some killing intent should have Tom tryna off himself.
Prep is honestly useless for Tom as there is nothing he can really do with it for the fight as any wards are hilariously outgunned by Oro's raw strength, taking over the Ministry isn't really an accomplishment and is also useless here, can't even bring an army of Death Eaters as thats outside help etc etc. I doubt he can even learn much about Oro either as Kabutomaru could set up seals to prevent outside detection so this should stop any clairvoyance attempts and his ability to resist genjutsu would let him stop any legilimency attempts. Two months for Oro on the other hand is far too much for reasons explained by Orc above.