OECD Issues Public Discussion Draft on Branch Mismatch Structures under BEPS Action 2
On 22 August 2016, the OECD issued a public discussion draft that deals with branch mismatch structures under Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the BEPS Project. The discussion draft identifies five basic types of branch mismatch arrangements where the ordinary tax accounting rules for allocating income and expenditure between the branch and head office resu…
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