Matthew Mortimer and Kirsten Hunt (Mayer Brown) consider the application to UK loan structures of recent changes to the UK’s anti-hybrid rules.
Finance Act 2021 has recently made important changes to the UK’s anti-hybrid rules in TIOPA 2010 Part 6A.
The changes not only apply to structures under which a UK company borrows money from connected and external lenders (referred to below as ‘UK loan structures’) but they are particularly relevant to them.
The following paragraphs are intended as an overview of how the changes generally improve the application of the anti-hybrid rules in this area although given the complexity of the subject matter that overview is necessarily detailed.
In this regard the date on which a particular change to the anti-hybrid rules takes effect will depend upon the nature of the change and in the main is outside the scope of this...
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Matthew Mortimer and Kirsten Hunt (Mayer Brown) consider the application to UK loan structures of recent changes to the UK’s anti-hybrid rules.
Finance Act 2021 has recently made important changes to the UK’s anti-hybrid rules in TIOPA 2010 Part 6A.
The changes not only apply to structures under which a UK company borrows money from connected and external lenders (referred to below as ‘UK loan structures’) but they are particularly relevant to them.
The following paragraphs are intended as an overview of how the changes generally improve the application of the anti-hybrid rules in this area although given the complexity of the subject matter that overview is necessarily detailed.
In this regard the date on which a particular change to the anti-hybrid rules takes effect will depend upon the nature of the change and in the main is outside the scope of this...
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:
