CASE HUB ARCHIVED–this archived case hub reflects the position at the date of the decision of 28 May 2014; it is no longer maintained. See further, timeline, commentary and related cases. Case facts Outline European Commission merger investigation into the planned acquisition by Hutchison 3G UK of Telefónica Ireland (Case M.6992). Latest developments The Commission cleared the transaction subject to commitments on 28 May 2014. The commitments accepted are in two parts: (1) a package aimed at ensuring the short-term entry of two MVNOs, with an option for one to become a full MNO by acquiring spectrum later—H3G has committed to sell up to 30% of the merged company's network capacity to two MVNOs in Ireland at fixed payment for a dedicated 'pipe' from the network–the Commission has found this to be more viable for the Irish market than the typical pay-as-you-go model in the rest of Europe. Five blocks of spectrum will then be divested from 01/01/2016 for ten years. (2) a package aimed at ensuring Eircom remains a competitive MNO in Ireland, namely continuing

An arrangement where only one type of benefit will ultimately be provided, but the type of benefit that will be provided is not known in advance because it will depend on certain given circumstances at the point benefits are drawn.

Funds which use common features from both closed-ended funds and open-ended funds may also have a lock-in period.

The UK’s rules on hybrid and other mismatches (referred to in this Practice Note as the hybrid rules) have applied since 1 January 2017 and aim to counteract tax mismatches that arise from the way in which a hybrid instrument or a hybrid entity is treated for tax purposes. Although the hybrid rules normally apply to cross-border transactions involving two or more jurisdictions, they can also apply to purely UK domestic transactions. Specifically, the hybrid rules target: • deduction/non-inclusion mismatches (D/NI mismatches), ie where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but not included in the taxable income of a payee or a related party investor, and • double deduction cases (DD cases), ie where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction The hybrid rules deal with different categories of D/NI mismatches and DD cases in separate chapters. In each case, the relevant hybrid rules only

The UK’s rules on hybrid and other mismatches (referred to in this Practice Note as the hybrid rules) have applied since 1 January 2017 and aim to counteract tax mismatches that arise from the way in which a hybrid instrument or a hybrid entity is treated for tax purposes. Although the hybrid rules normally apply to cross-border transactions involving two or more jurisdictions, they can also apply to purely UK domestic transactions. Specifically, the hybrid rules target: • deduction/non-inclusion mismatches (D/NI mismatches), ie where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but not included in the taxable income of a payee or a related party investor, and • double deduction cases (DD cases), ie where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction The hybrid rules deal with different categories of D/NI mismatches and DD cases in separate chapters. In each case, the relevant hybrid rules only apply if the relevant conditions have been satisfied. For more information

The UK’s rules on hybrid and other mismatches (referred to in this Practice Note as the hybrid rules) have applied since 1 January 2017 and aim to counteract tax mismatches that arise from the way in which a hybrid instrument or a hybrid entity is treated for tax purposes. Although the hybrid rules normally apply to cross-border transactions involving two or more jurisdictions, they can also apply to purely UK domestic transactions. Specifically, the hybrid rules target: • deduction/non-inclusion mismatches (D/NI mismatches), ie where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but not included in the taxable income of a payee or a related party investor, and • double deduction cases (DD cases), ie where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction For more information on the hybrid rules, see Practice Note: Hybrid mismatches—introduction to the rules. For an overview in table format of the conditions required by each chapter before any counteraction can apply, see: UK rules

The UK’s rules on hybrid and other mismatches (referred to in this Practice Note as the hybrid rules) have applied since 1 January 2017 and aim to counteract tax mismatches that arise from the way in which a hybrid instrument or a hybrid entity is treated for tax purposes. Although the hybrid rules normally apply to cross-border transactions involving two or more jurisdictions, they can also apply to purely UK domestic transactions. Specifically, the hybrid rules target: • deduction/non-inclusion mismatches (D/NI mismatches), ie where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but not included in the taxable income of a payee or a related party investor, and • double deduction cases (DD cases), ie where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction The hybrid rules deal with different categories of D/NI mismatches and DD cases in separate chapters. In each case, the relevant hybrid rules only apply if the relevant conditions have been satisfied. For

The UK’s rules on hybrid and other mismatches (referred to in this Practice Note as the hybrid rules) have applied since 1 January 2017 and aim to counteract tax mismatches that arise from the way in which a hybrid instrument or a hybrid entity is treated for tax purposes. Although the hybrid rules normally apply to cross-border transactions involving two or more jurisdictions, they can also apply to purely UK domestic transactions. Specifically, the hybrid rules target: • deduction/non-inclusion mismatches (D/NI mismatches), ie where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but not included in the taxable income of a payee or a related party investor, and • double deduction cases (DD cases), ie where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction The hybrid rules deal with different categories of D/NI mismatches and DD cases in separate chapters. In each case, the relevant hybrid rules only apply if the relevant conditions have been satisfied. For

The UK’s rules on hybrid and other mismatches (referred to in this Practice Note as the hybrid rules) have applied since 1 January 2017 and aim to counteract tax mismatches that arise from the way in which a hybrid instrument or a hybrid entity is treated for tax purposes. Although the hybrid rules normally apply to cross-border transactions involving two or more jurisdictions, they can also apply to purely UK domestic transactions. Specifically, the hybrid rules target: • deduction/non-inclusion mismatches (D/NI mismatches), ie where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but not included in the taxable income of the payee or a related party investor, and • double deduction cases (DD cases), ie where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction The hybrid rules deal with different categories of D/NI mismatches and DD cases in separate chapters. For more information on the hybrid rules, see Practice Note: Hybrid mismatches—introduction to the rules. For an overview in table format of the

The UK’s rules on hybrid and other mismatches (referred to in this Practice Note as the hybrid rules) have applied since 1 January 2017 and aim to counteract tax mismatches that arise from the way in which a hybrid instrument or a hybrid entity is treated for tax purposes. Although the hybrid rules normally apply to cross-border transactions involving two or more jurisdictions, they can also apply to purely UK domestic transactions. Specifically, the hybrid rules target: • deduction/non-inclusion mismatches (D/NI mismatches), ie where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but not included in the taxable income of the payee or a related party investor, and • double deduction cases (DD cases), ie where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction The hybrid rules deal with different categories of D/NI mismatches and DD cases in separate chapters. In each case, the relevant hybrid rules only apply if the relevant conditions have

The UK’s rules on hybrid and other mismatches (referred to in this Practice Note as the hybrid rules) have applied since 1 January 2017 and aim to counteract tax mismatches that arise from the way in which a hybrid instrument or a hybrid entity is treated for tax purposes. Although the hybrid rules normally apply to cross-border transactions involving two or more jurisdictions, they can also apply to purely UK domestic transactions. Specifically, the hybrid rules target: • deduction/non-inclusion mismatches (D/NI mismatches), ie where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but not included in the taxable income of the payee or a related party investor, and • double deduction cases (DD cases), ie where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction The hybrid rules deal with different categories of D/NI mismatches and DD cases in separate chapters. In each case, the relevant hybrid rules only apply if the relevant

The UK’s rules on hybrid and other mismatches (referred to in this Practice Note as the hybrid rules) have applied since 1 January 2017 and aim to counteract tax mismatches that arise from the way in which a hybrid instrument or a hybrid entity is treated for tax purposes. Although the hybrid rules normally apply to cross-border transactions involving two or more jurisdictions, they can also apply to purely UK domestic transactions. Specifically, the hybrid rules target: • deduction/non-inclusion mismatches (D/NI mismatches), ie where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but not included in the taxable income of a payee or a related party investor, and • double deduction cases (DD cases), ie where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction The hybrid rules deal with different categories of D/NI mismatches and DD cases in separate chapters. In each case, the relevant hybrid rules only apply if the relevant conditions have been satisfied. For more