HMRC response to hybrid mismatch rules consultation—close, but no cigar

Table of contents

• Key takeaways
• Continued double taxation of US multinationals—disregarded payments
• Continued double taxation of US multinationals—dual consolidated losses
• Narrowing of illegitimate overseas deduction, but not far enough?
• Imported mismatches—good and bad

Article summary

Tax analysis: Kate Alexander, James A D Wilson, Patrick J O’Gara, Claudine Fox and Nick Evans of Baker & McKenzie LLP analyse the outcome of the hybrid mismatch rules consultation and the proposed legislative changes following the consultation outcome.