On 22 August 2016, the OECD issued a public discussion draft that deals with 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 where the ordinary tax accounting rules for allocating income and expenditure between the branch and head office result in a portion of the net income of the taxpayer falling out of the charge to taxation in both the …