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UK Explains Amendments to Finance Bill 2016 Concerning the Patent Box, Capital Gains Tax Reduction and Hybrid Mismatches

06 September 2016

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Proposed Changes

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United Kingdom

On 1 September 2016, UK HM Treasury published explanatory notes for amendments to the Finance Bill 2016 concerning changes to the patent box, the capital gains tax reduction, and the anti-avoidance legislation for hybrids and other mismatches. The main amendments are summarized as follows. Amendments 1-131 and 154-160 to Clause 65: Hybrid and other mismatches The hybrid and other mismatches amendments are intended to clarify the scope and application of this anti-avoidance legislation, and include: Amendments in relation to mismatches involving permanent establishments (PEs), which clarify the interaction between the hybrid mismatch rules and the existing UK foreign PE exemption...