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Posted 2 weeks ago

by My Taxpartner

  • UK
  • Standard

UK Anti-hybrid legislation

Finance Act 2016 included new legislation in respect of Hybrid and Other Mismatches, in response to the OECD’s Recommendations on Action 2 of the BEPS Project. This legislation aims to counteract tax advantages arising due to mismatches in the way certain entities, instruments and transactions are treated for tax purposes and came into effect on 1 January 2017.

It is important to note that these Anti-hybrid rules could be applicable not only to financing arrangements but also to a wide range of other transactions involving mismatches which relate to any type of payment to or by a hybrid entity. Furthermore the rules also apply to mismatches arising involving companies with overseas permanent establishments (PE’s).

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