On 27 July 2017, the OECD published a report on Neutralizing the Effects of Branch Mismatch Arrangements. The following is the summary provided with the OECD report:
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 Neutralizing the Effects of Hybrids Mismatch Arrangements (Action 2 Report). Branch mismatches arise where the ordin…