Policy paper

Corporation Tax: anti-hybrid rules

This applies to large multinational groups with UK parent or subsidiary companies involved in cross-border or domestic transactions involving a mismatch in the tax treatment.

• From: HM Revenue & Customs
• Published: 9 December 2015
• Last updated: 22 December 2015 — See all updates

This publication was withdrawn on 17 March 2016

This information has been updated please read Corporation Tax: anti-hybrids rules policy paper.

Documents

Corporation Tax: anti-hybrid rules

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Draft clause 33

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Draft explanatory notes clause 33

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Draft examples - clause 33: hybrid and other mismatches

PDF, 1.61 MB, 85 pages

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Details

This information has been updated please read Corporation Tax: anti-hybrids rules policy paper.

This legislation neutralises the tax mismatch created by the hybrid arrangement by changing the tax treatment of either the payment or the receipt, depending on the circumstances. The rules work whether both or just one country affected by the arrangement have introduced the Organisation for Economic Co-operation and Development (OECD) rules. A series of examples illustrating the application of the hybrid mismatch rules will be published on 22 December 2015.

Published 9 December 2015
Last updated 22 December 2015 + show all updates

1. 22 December 2015

   A series of examples illustrating the application of the hybrid mismatch rules have been added.

2. 9 December 2015

   First published.