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UK proposes to amend hybrid and other mismatches regime – implications for US multinationals

17 November 2020

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Tax Alerts, Legislation & Policy, National/Federal Taxation, OECD

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United States, United Kingdom, European Union

Executive summaryOn 12 November 2020, the United Kingdom (UK) Government published its response to a consultation document alongside limited draft legislation for some changes proposed to the UK hybrid and other mismatches regime.In particular, HM Revenue & Customs (HMRC) has accepted that many of the rules as currently drafted have a disproportionate outcome. In order to address the issues which have been raised, legislative change is required, some of which will have retrospective effect back to the commencement of the regime on 1 January 2017. However, some changes will only have prospective effect from the date that the Finance Act 2021 receives...