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UK Publishes Finance Bill 2016 Amendments Concerning Hybrid Mismatches and GAAR

25 July 2016

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Proposed Changes

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United Kingdom

On 21 July 2016, UK HM Treasury published a number of government amendments in the report stage of Finance Bill 2016. The main amendments concern hybrid and other mismatches, and the General Anti-Abuse Rule. Amendments 1 to 131 to Clause 65: Hybrid and other mismatches The key changes 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 rules; Amendments that clarify the treatment of income and expenses allocated within a company; Amendments that clarify the interaction between the hybrid mismatch rules and the...