Business tax – policy paper

Corporation Tax: anti-hybrid rules

This publication was withdrawn on 17 March 2016

This information has been updated please read Corporation Tax: anti-hybrids rules policy paper.

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.

Documents

Draft clause 33

This file may not be suitable for users of assistive technology. Request an accessible format.

If you use assistive technology (eg a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gsi.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Draft explanatory notes clause 33

This file may not be suitable for users of assistive technology. Request an accessible format.

If you use assistive technology (eg a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gsi.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Draft examples - clause 33: hybrid and other mismatches

This file may not be suitable for users of assistive technology. Request an accessible format.

If you use assistive technology (eg a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gsi.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Detail

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.