The UK hybrid rules impose double taxation as currently enacted, explain Nick Evans and Claudine Fox (Baker McKenzie). Changes will be made, but do they go far enough?
The Finance (No.2) Bill 2021 received its first reading in the House of Commons on 11 March. Schedule 7 to the Bill contains important amendments to the hybrid and other mismatch rules contained within TIOPA 2010 Part 6A (‘the rules’). These amendments were announced following HMRC’s consultation on the operation of the rules during the course of 2020.
Taxpayers will be pleased that the amendments seek to address the risk of economic double taxation that has resulted from the operation of the rules since 2017. Unfortunately the amendments leave several known issues unaddressed and therefore this exposure will continue to exist for some.
When enacted this will be the third Finance Act in four years to contain retroactive amendments that...
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The UK hybrid rules impose double taxation as currently enacted, explain Nick Evans and Claudine Fox (Baker McKenzie). Changes will be made, but do they go far enough?
The Finance (No.2) Bill 2021 received its first reading in the House of Commons on 11 March. Schedule 7 to the Bill contains important amendments to the hybrid and other mismatch rules contained within TIOPA 2010 Part 6A (‘the rules’). These amendments were announced following HMRC’s consultation on the operation of the rules during the course of 2020.
Taxpayers will be pleased that the amendments seek to address the risk of economic double taxation that has resulted from the operation of the rules since 2017. Unfortunately the amendments leave several known issues unaddressed and therefore this exposure will continue to exist for some.
When enacted this will be the third Finance Act in four years to contain retroactive amendments that...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
