Open consultation

Hybrid and other mismatches - draft guidance

This consultation closes on


We are seeking comments on this draft guidance on the hybrids mismatch legislation.


Consultation description

This draft guidance is provided to assist understanding of the application of the hybrids mismatch legislation, which take effect from 1 January 2017.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.

Ways to respond