UK and International Tax news

HMRC Issues Updated Guidance On Hybrids And Other Mismatches

Tuesday 11th April 2017

HMRC has recently published updated draft guidance on hybrids and other mismatches following the receipt of responses on draft guidance issued in December 2016 in relation to legislation, which was introduced by FA 2016 and which take effect from 1st January 2017.

HMRC have included examples based on 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.

In the updated guidance, HMRC has adopted some of the suggestions received from the responses and corrected certain inconsistencies. There is ongoing engagement with respondents to provide additional material before the guidance is finalised.

HMRC will migrate the guidance into the International Manual over the next six months, once the additional material has been provided and worked through. HMRC will continue to monitor use of the guidance and to add to it where additional material may be helpful.

If you would like further information on the above, please contact Keith Rushen on 0207 486 2378.

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