Overview
OECD Releases Discussion Draft on Branch Mismatch Structures: The Organization for Economic Cooperation and Development (OECD) released a discussion draft on “branch mismatch structures” under Action 2 (Neutralizing the Effects of Hybrids Mismatch Arrangements) of its base erosion and profit shifting (BEPS) action plan. Branch mismatches occur where the jurisdictions in which the head office and a branch office of a taxpayer are located take a different view as to the allocation of income and expenses between the head office and branch office and include situations where the branch jurisdiction does not treat the taxpayer as having a taxable presence in that jurisdiction. The discussion draft identifies five types of branch mismatches and makes recommendations intended to address each type. Interested parties are invited to provide comments by September 19.