UK Publishes Draft Guidance on Hybrid Mismatch

UK Publishes Draft Guidance on Hybrid Mismatch
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UK Publishes Draft Guidance on Hybrid Mismatch
December 14th, 2016
On December 9, The HM Revenue & Customs published draft tax guidance to assist understanding of the application of the hybrids mismatch legislation that comes into effect on January 1, 2017. The HMRC seeks comments on the draft guidance on the hybrids mismatch legislation.

On December 9, The HM Revenue & Customs published draft tax guidance to assist understanding of the application of the hybrids mismatch legislation that comes into effect on January 1, 2017. The HMRC seeks comments on the draft guidance on the hybrids mismatch legislation.

Examples to Provide Clarity

This guidance aims, through explanation and examples, to assist in understanding the application of the hybrids legislation introduced by Finance Act 2016, which has effect from 1 January 2017. The examples contained are based upon a selection of those contained within the OECD ‘Final Report on Neutralising the Effects of Hybrid Mismatch Arrangements’, with additional draft examples dealing with hybrid transfers and permanent establishments.

The Content

The guidance largely follows the structure of the legislation. For each of the areas below the guidance gives a general overview of the legislation and how it is intended to apply, followed by more detailed analysis, and specific examples where appropriate.

The following subjects are covered:

  1. Financial Instruments & Hybrid Transfers;
  2. Hybrid Payer, Hybrid Payee & Multinational Payee;
  3. Transfers by UK Permanent Establishments of multinational companies;
  4. Hybrid Entity;
  5. Dual Territory Double Deduction;
  6. Imported Mismatches;
  7. Other Provisions & Anti-avoidance;
  8. Operational guidance

Comments on the draft guidance are invited by 10 March 2017. Responses should be sent to hybrids.mailbox@hmrc.gsi.gov.uk

Sources: HMRC - Press Release, Draft Guidance - Hybrid and Other Mismatches
 

UK Publishes Draft Guidance on Hybrid Mismatch
; posted on
December 14th, 2016
On December 9, The HM Revenue & Customs published draft tax guidance to assist understanding of the application of the hybrids mismatch legislation that comes into effect on January 1, 2017. The HMRC seeks comments on the draft guidance on the hybrids mismatch legislation.
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