The OECD, on 27 July 2017, released its report, Neutralising the Effects of Branch Mismatch Arrangements Action 2 (see previous coverage). The report recommends domestic law changes to neutralise the effect of certain payments or deemed payments involving branches. These recommendations are not a minimum standard, but some countries may choose to adopt all or part of them. Companies will have to consider carefully whether any of their current arrangements may be adversely affected by the rules if adopted by relevant countries. This may not always be straightforward, e.g. in the context of imported branch mismatches.
Further insights and comments can be found here.
Please contact your local PwC contact or Evi Geerts, Pieter Deré or Maarten Temmerman for any questions.