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

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

Published on: 18 December 2020

Published by: LexisPSL

HMRC response to hybrid mismatch rules consultation—close, but no cigar
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. Sign in or take a trial to read the full analysis.

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