On 22 August 2016, the OECD released a discussion draft (the draft) on branch mismatch structures under Action 2 of the Action Plan on Base Erosion and Profit Shifting (AP-BEPS). The mismatches include the following:
The draft applies the analysis and recommendations of Action 2 to mismatches that may arise through the use of branch structures. The document is available here: http://www.oecd.org/tax/beps/Discussion-draft-Action-2-Branch-mismatch-structures.pdf
The OECD invites interested parties to submit their comments by 19 September 2016. The comments should be sent by email to firstname.lastname@example.org and be addressed to the International Co-operation and Tax Administration Division, OECD/CTPA.