Mark Middleditch (Allen & Overy) provides an update of recent developments, including: the announcement of new rules on hybrid mismatches; the high-risk promoters regulations; euro conversion clauses; FATCA; and the EC investigation into the Irish tax rulings over Apple
On 5 October HM Treasury announced a ‘clampdown’ on hybrid mismatches. Rather oddly this was on a Sunday; perhaps coincidentally it was also the start of the Liberal Democrat annual conference.
HM Treasury says that hybrid mismatch arrangements exploit the differences between countries’ tax rules to avoid paying tax in either country or to obtain more tax relief against profits than multinationals are entitled to. The press release is rather scant in terms of other details (such as the types of arrangements that will be caught and measures...
