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OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS

2017-07-27
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Release : 2017-07-27
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Book Rating : 796/5 ( reviews)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS written by OECD. This book was released on 2017-07-27. Available in PDF, EPUB and Kindle. Book excerpt: 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).

Neutralising the Effects of Branch Mismatch Arrangements, Action 2

2017 Corporations
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Release : 2017
Genre : Corporations
Kind : eBook
Book Rating : 953/5 ( reviews)

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Book Synopsis Neutralising the Effects of Branch Mismatch Arrangements, Action 2 by : Organization for Economic Development and Cooperation

Download or read book Neutralising the Effects of Branch Mismatch Arrangements, Action 2 written by Organization for Economic Development and Cooperation. This book was released on 2017. Available in PDF, EPUB and Kindle. Book excerpt: 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.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report

2015-10-05
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Release : 2015-10-05
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Book Rating : 132/5 ( reviews)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report written by OECD. This book was released on 2015-10-05. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements

2014-09-16
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Release : 2014-09-16
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Book Rating : 815/5 ( reviews)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements written by OECD. This book was released on 2014-09-16. Available in PDF, EPUB and Kindle. Book excerpt: This report, produced by the OECD/G20 Project on Base Erosion and Profit Shifting sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements.

OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, The Bahamas (Stage 2) Inclusive Framework on BEPS: Action 14

2022-04-14
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Release : 2022-04-14
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Book Rating : 355/5 ( reviews)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, The Bahamas (Stage 2) Inclusive Framework on BEPS: Action 14 by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, The Bahamas (Stage 2) Inclusive Framework on BEPS: Action 14 written by OECD. This book was released on 2022-04-14. Available in PDF, EPUB and Kindle. Book excerpt: This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by the Bahamas.

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