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Government to consult on new hybrid measures

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The government has confirmed it will publish a consultation document at the Autumn Statement later this year on new measures to prevent multinational companies exploiting differences between countries’ tax rules through the use of ‘hybrid mismatch’ arrangements.

The government has confirmed it will publish a consultation document at the Autumn Statement later this year on new measures to prevent multinational companies exploiting differences between countries’ tax rules through the use of ‘hybrid mismatch’ arrangements. The consultation will also consider special provisions for banks’ and insurers’ hybrid regulatory capital instruments.

Hybrid mismatch arrangements exploit differences between countries’ tax rules to avoid paying tax in either country, or to obtain more tax relief against profits than they are entitled to. The arrangements are the focus of action 2 of the OECD’s BEPS action plan on international corporate tax avoidance. The government expects the new rules to generate ‘tens of millions of pounds per year of additional revenue’ for the exchequer.

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