Legal News

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. or take a trial to read the full analysis.

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