Jeanette Zaman (Slaughter and May) considers the draft legislation on hybrid mismatch arrangements and discusses their application to commercial transactions and the potential significance of the imported mismatch rules.
The OECD published its final BEPS reports on 5 October 2015 and the report on Action 2 set out the OECD’s proposals in relation to hybrid mismatch arrangements (the ‘Action 2 report’) (see ‘Hybrids: the UK and OECD proposals’ (Tom Scott) Tax Journal 31 October 2015). The UK published draft legislation to be introduced in a new Part 6A into TIOPA 2010 (replacing the existing anti-arbitrage rules) in December 2015 along with the summary of responses to the UK consultation document (the Summary of responses see www.bit.ly/1RIj4Q0).
Perhaps unsurprisingly in light of the length of the Action 2 report the draft legislation is not for the...
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:
Jeanette Zaman (Slaughter and May) considers the draft legislation on hybrid mismatch arrangements and discusses their application to commercial transactions and the potential significance of the imported mismatch rules.
The OECD published its final BEPS reports on 5 October 2015 and the report on Action 2 set out the OECD’s proposals in relation to hybrid mismatch arrangements (the ‘Action 2 report’) (see ‘Hybrids: the UK and OECD proposals’ (Tom Scott) Tax Journal 31 October 2015). The UK published draft legislation to be introduced in a new Part 6A into TIOPA 2010 (replacing the existing anti-arbitrage rules) in December 2015 along with the summary of responses to the UK consultation document (the Summary of responses see www.bit.ly/1RIj4Q0).
Perhaps unsurprisingly in light of the length of the Action 2 report the draft legislation is not for the...
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:
