Corporation Tax: changes to the hybrid and other mismatches regime - technical note
This technical note advises of 2 minor changes to the hybrid mismatch regime which will be introduced in Finance Bill 2017 and will take effect from 1 January 2017.
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The Hybrid and other Mismatches regime was introduced by Finance Act 2016. Schedule 10 of FA 2016 inserted Part 6A (Hybrids and Other Mismatches) into the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010).
As announced at Autumn Statement 2016, the government intends to make 2 minor changes to the hybrid mismatch regime. These changes will be introduced in Finance Bill 2017, but the changes will be effective from 1 January 2017 – the commencement date of the hybrid mismatch regime. These changes are both relieving provisions and will enable the hybrid mismatch rules to operate as intended.