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The 44 responses from stakeholders and 9 stakeholder meetings provided a range of suggested enhancements and additions to the draft guidance. A summary of the main themes identified, and a list of respondents, is provided.
In the attached updated guidance HMRC has adopted some of the suggestions and corrected any inconsistencies. There is an ongoing engagement with the respondents to provide additional material before the guidance is finalised.
HMRC will migrate the guidance into the International Manual over the next 6 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.
This draft guidance is provided to assist understanding of the application of the hybrids mismatch legislation, which take effect from 1 January 2017.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.