Matthew Herrington and Greg Smythe (KPMG) review some of the proposed changes to the hybrid mismatch rules under Finance (No. 2) Bill2017 and last November’s revised draft guidance on their interpretation.
This article follows our earlier article (‘Examining HMRC’s revised draft guidance on hybrids’ Tax Journal on 27 April 2017).
The UK’s legislation on the hybrid mismatch rules is now within TIOPA 2010 Part 6A and all references below are to that Act unless stated otherwise.
HMRC has proposed changes to these rules under the Finance (No. 2) Bill 2017 (published on 1 December 2017) which is anticipated to receive royal assent by the end of January (with no changes arising from the parliamentary debate on 11 January). This article starts by explaining some of these changes.
This article also considers the key changes in the revised guidance published on 29 November 2017 which clarifies how...
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:
Matthew Herrington and Greg Smythe (KPMG) review some of the proposed changes to the hybrid mismatch rules under Finance (No. 2) Bill2017 and last November’s revised draft guidance on their interpretation.
This article follows our earlier article (‘Examining HMRC’s revised draft guidance on hybrids’ Tax Journal on 27 April 2017).
The UK’s legislation on the hybrid mismatch rules is now within TIOPA 2010 Part 6A and all references below are to that Act unless stated otherwise.
HMRC has proposed changes to these rules under the Finance (No. 2) Bill 2017 (published on 1 December 2017) which is anticipated to receive royal assent by the end of January (with no changes arising from the parliamentary debate on 11 January). This article starts by explaining some of these changes.
This article also considers the key changes in the revised guidance published on 29 November 2017 which clarifies how...
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:
