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.
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.