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Peter A. Harrisbasis for making such a distinction (and the question arises whether itis practical to do so). The OECD Action 2 — 2014 Deliverable refers tothe former, but not to the latter. 35There are points at which the OECD Public Discussion Drafton BEPS Action 2 — Domestic Issues deals with the bifurcation of anamount into two parts of a different character, for example, revenue andcapital. 36 However, this is a matter of identifying a particular payment(as opposed to two payments) and characterization. It is not a matterof pure quantification. Again, the OECD Action 2 — 2014 Deliverableand OECD Public Discussion Draft on BEPS Action 2 — DomesticIssues do not make connections in this regard or expressly coordinatewith Actions 8, 9 and 10.While there is some uncertainty about the scope of Action 2 inthe OECD Public Discussion Draft on BEPS Action 2 — Domestic Issues,it is supported with 21 worked examples (“Figures”) which reveal muchabout the scope of the proposals. The OECD Action 2 — 2014 Deliverablereproduces only seven of these examples, but the others may yet reappearin further work of the OECD on this topic. The table in annex I of thepresent chapter attempts to categorize the OECD examples by referenceto the conceptual framework outlined in section 1 above and throughcomparison with the 13 examples discussed there. The 13 examples areintentionally spread across the potential types of mismatch. By comparison,the numbers in square brackets in the OECD examples are to thefigures in the OECD Action 2 — 2014 Deliverable.The OECD Public Discussion Draft on BEPS Action 2 — DomesticIssues contains no pure examples of mismatches with respect to payments,only such mismatches triggered by mismatches in allocation andcharacter of assets and identification of persons. The OECD examplesfocus on mismatches regarding ownership of assets, character of assets,identification of persons and dual residence. This raises fundamentalquestions with respect to whether any other types of mismatches are35For example, OECD Action 2 — 2014 Deliverable, supra note 2, 72.36For example, see OECD Public Discussion Draft on BEPS Action2 — Domestic Issues, supra note 2, figure 19, 73, where the bifurcation isbetween financing expense and purchase price (discussed further in the textbelow). The OECD Action 2 — 2014 Deliverable does not repeat this example.216