Tax and the City briefing for January 2016

 

For those challenged by the new hybrid mismatch rules there was at least some Christmas cheer when 85 pages of practical examples were published by HMRC on 22 December (www.bit.ly/1SzlKi8). The new legislation included in the draft Finance Bill 2016 clauses published on 9 December forms part of the UK’s response to BEPS and will apply with effect from 1 January 2017.

 

The examples which are supposed to assist understanding of the new UK legislation are based on the OECD final BEPS report Neutralising the effects of hybrid mismatch arrangements with some additional examples on hybrid transfers. Further guidance is promised later in 2016. 

 

Mismatches arising under financial...