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UK Publishes Draft Examples of the Treatment of Hybrid Mismatches under Proposed Rules to Neutralize their Effects

|Proposed Changes|United Kingdom
United Kingdom

On 22 December 2015, the UK HMRC published 20 examples of how the draft hybrid mismatch rules included in the Finance Bill 2016 will be applied. The examples are provided in seven main categories, including:

  • Hybrid and other Mismatches from Financial Instruments;
  • Hybrid Transfer Deduction/Non-inclusion Mismatches;
  • Hybrid Payer Deduction/Non-inclusion Mismatches;
  • Hybrid Payee Deduction/Non-inclusion Mismatches;
  • Hybrid Entity Double Deduction Mismatches;
  • Dual Resident Company Double Deduction …

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