On 23 September 2016, the OECD published comments received on the public discussion draft on 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 and sets out preliminary recommendations for domestic rules, based on those in the Action 2 Report, which would neutralize the mismatch in tax outcomes ({News-2016-08-23/P/3- previous coverage}).
Clic…