Neutralising the effects of branch mismatch arrangements, Action 2 - Organisation for Economic Co-operation and Development - Bøker - Organization for Economic Co-operation a - 9789264277953 - 14. august 2017
Ved uoverensstemmelse mellom cover og tittel gjelder tittel

Neutralising the effects of branch mismatch arrangements, Action 2

Organisation for Economic Co-operation and Development

Legg til iMusic ønskeliste

Neutralising the effects of branch mismatch arrangements, Action 2

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.

Media Bøker     Pocketbok   (Bok med mykt omslag og limt rygg)
Utgitt 14. august 2017
ISBN13 9789264277953
Utgivere Organization for Economic Co-operation a
Antall sider 99
Mål 210 × 270 × 5 mm   ·   249 g
Språk Engelsk  

Vis alle

Mer med Organisation for Economic Co-operation and Development