The Finance Bill hybrid mismatch legislation significantly expands the scope of the December draft legislation. James Ross (McDermott Will & Emery) reviews the changes.
The recent Budget re-emphasised the government’s desire to be at the vanguard of BEPS implementation. Having already legislated for country by country reporting in last year’s Finance Act the 2016 Bill includes provisions (FB 2016 cl 71) to update the transfer pricing rules to reflect the changes proposed in the BEPS Actions 8–10 reports and next year’s Bill will introduce proposals on the restrictions on interest deductibility in line with BEPS Action 4.
The government also reconfirmed its intention to introduce comprehensive hybrid mismatch proposals from January 2017 in line with BEPS Action 2 report. Whilst the Finance Bill provisions largely follow the draft published in December there is a significant extension to their scope ...
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:
The Finance Bill hybrid mismatch legislation significantly expands the scope of the December draft legislation. James Ross (McDermott Will & Emery) reviews the changes.
The recent Budget re-emphasised the government’s desire to be at the vanguard of BEPS implementation. Having already legislated for country by country reporting in last year’s Finance Act the 2016 Bill includes provisions (FB 2016 cl 71) to update the transfer pricing rules to reflect the changes proposed in the BEPS Actions 8–10 reports and next year’s Bill will introduce proposals on the restrictions on interest deductibility in line with BEPS Action 4.
The government also reconfirmed its intention to introduce comprehensive hybrid mismatch proposals from January 2017 in line with BEPS Action 2 report. Whilst the Finance Bill provisions largely follow the draft published in December there is a significant extension to their scope ...
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:
