UK Consults on Draft Guidance on New Hybrid Mismatch Rules
UK HMRC has published draft guidance on hybrid and other mismatches for public consultation. The draft guidance concerns new rules based on guidance developed as part of BEPS Action 2. The following is a brief summary of the rules and guidance.
The New Rules
The new rules apply to several hybrid mismatch types, including hybrid and other mismatches from financial Instruments, hybrid transfer…
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