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The Resource Neutralising the effects of branch mismatch arrangements, Action 2 - inclusive framework on BEPS

Neutralising the effects of branch mismatch arrangements, Action 2 - inclusive framework on BEPS

Label
Neutralising the effects of branch mismatch arrangements, Action 2 - inclusive framework on BEPS
Title
Neutralising the effects of branch mismatch arrangements, Action 2 - inclusive framework on BEPS
Subject
Language
eng
Summary
This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report). Branch mismatches arise where the ordinary rules for allocating income and expenditure between the branch and head office result in a portion of the net income of the taxpayer escaping the charge to taxation in both the branch and residence jurisdiction. Unlike hybrid mismatches, which result from conflicts in the legal treatment of entities or instruments, branch mismatches are the result of differences in the way the branch and head office account for a payment made by or to the branch. The 2017 report identifies five basic types of branch mismatch arrangements that give rise to one of three types of mismatches: deduction / no inclusion (D/NI) outcomes, double deduction (DD) outcomes, and indirect deduction / no inclusion (indirect D/NI) outcomes. This report includes specific recommendations for improvements to domestic law intended to reduce the frequency of branch mismatches as well as targeted branch mismatch rules which adjust the tax consequences in either the residence or branch jurisdiction in order to neutralise the hybrid mismatch without disturbing any of the other tax, commercial or regulatory outcomes. The annexes of the report summarise the recommendations and set out a number of examples illustrating the intended operation of the recommended rules
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
Series statement
OECD/G20 Base Erosion and Profit Shifting Project
Series volume
Action 2
http://library.link/vocab/subjectName
  • OECD
  • BEPS Project (OECD)
  • Inclusive Framework (OECD)
  • branch
  • head office
  • exemption
  • tax treaty
Label
Neutralising the effects of branch mismatch arrangements, Action 2 - inclusive framework on BEPS
Instantiates
Publication
Extent
99 p.
Isbn
9789264277953
Isbn Type
(print)
Issn
  • 2313-2604 (print)
  • 2313-2612 (online)
Label
Neutralising the effects of branch mismatch arrangements, Action 2 - inclusive framework on BEPS
Publication
Extent
99 p.
Isbn
9789264277953
Isbn Type
(print)
Issn
  • 2313-2604 (print)
  • 2313-2612 (online)

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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