Ceinwen Rees and Richard Ward (Debevoise & Plimpton) explain how the UK’s anti-hybrid rules may apply to a complex international private equity fund.
The Finance Bill hybrid mismatch legislation significantly expands the scope of the December draft legislation. James Ross (McDermott Will & Emery) reviews the changes.
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.
Tom Scott (McDermott Will & Emery) looks at hybrid arrangements and the effect of the OECD proposals.
Dominic Robertson (Slaughter and May) reports on the likely changes needed to group structures in light of BEPS, state aid challenges and the diverted profits tax
What can we expect from the forthcoming changes to the taxation of hybrid financial instruments, ask David Harkness and David McCann (Clifford Chance)
Sjoerd Douma & Bob van der Made, PwC, set out the key proposals.