The OECD invited interested parties to provide comments on branch mismatch structures under Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.
The OECD BEPS Action 2 Report on Neutralizing the Effects of Hybrids Mismatch Arrangements sets out recommendations for domestic rules designed to neutralize mismatches in tax outcomes that arise in respect of payments under a hybrid mismatch arrangement. The report recognizes three types of mismatches:
The OECD invites the public to comment on the five basic types of branch mismatch arrangements identified in the discussion document:
Members of the public are invited to comment on the preliminary recommendations set out in this document and are specifically requested to provide input on the “Questions for Consultation” highlighted at the end of each section.
Comments should be submitted by September 19, 2016 at the latest.
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