The OECD has released a discussion draft on branch mismatch structures under Action 2 of the BEPS Action Plan.
Action 2, titled Neutralising the Effects of Hybrid Mismatch Arrangements, recommends that countries change their domestic rules to neutralize the mismatches in tax outcomes that can arise in respect of payments under a hybrid mismatch arrangement. This OECD discussion draft applies the analysis and recommendations in the Action 2 report to mismatches that can arise through the use of branch structures.
The discussion draft identifies five types of branch mismatch arrangements:
Interested parties are invited to send comments on the questions for consultation in the draft discussion by September 19, 2016.
For more information, contact your KPMG adviser.
Information is current to August 30, 2016. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500