INTM550040 - Hybrids: introduction: scope of Part 6A, TIOPA 2010
Part 6A targets hybrid mismatches in the following circumstances
Deduction/non-inclusion outcomes involving
- Hybrid financial instruments
- Hybrid transfers
- Hybrid entity payers
- Hybrid entity payees
- Permanent establishments
Double deduction outcomes involving
- Hybrid entities
- Dual resident companies
- Permanent establishments
The legislation also includes rules to deal with arrangements where a mismatch arises entirely outside the UK and is part of the same ‘over-arching arrangement’ as a UK transaction: such arrangements are known as ‘imported’ mismatches. These additional rules are needed to ensure that the legislation cannot be by-passed by routing a mismatch via a third jurisdiction. The imported mismatch rules deal with double deduction or deduction/non-inclusion imported mismatch outcomes involving:
- Hybrid financial instruments
- Hybrid transfers
- Hybrid entity payees
- Hybrid entity payers
- Permanent establishments
- Dual resident companies