UK HMRC has published draft guidance on hybrid and other mismatches for public consultation. The draft guidance concerns new rules based on guidance developed as part of BEPS Action 2.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 mismatches, hybrid payer mismatches, hybrid payee mismatches, and others. Although specific rules apply for each mismatch type, the primary response in general is the disallowance of a deduction in the case of a UK payer and the...