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HMRC internal manual

International Manual

Hybrid and other mismatches

Hybrid and other mismatches

The guidance in relation to Part 6A of Taxation (International and Other Provisions) Act 2010 is set out at INTM850000 onwards.  These INTM pages are currently available as a PDF at

Previous drafts of this guidance remain available on at

Any queries or comments in relation to this guidance should be referred to the Base Protection Policy team, BAI

  • by email to:, or
  • by post to: HM Revenue & Customs                          Base Protection Policy Team, BAI

                             Room 3C/21

                             100 Parliament St

                             London, SW1A 2BQ