- 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
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.
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