Commentary

D4.701 Anti hybrid rules—summary

Corporate tax
Corporate tax | Commentary

D4.701 Anti hybrid rules—summary

Corporate tax | Commentary

Division D4.7     Hybrid entities

For updates affecting this Division please see Part D0 Updates

Hybrid and other mismatch arrangements

D4.701 Anti hybrid rules—summary

For the latest New Development, see ND.1656.

Finance Act 2016 introduced provisions into TIOPA 20101 which apply from 1 January 2017 to address arrangements that give rise to hybrid mismatch outcomes and generate a tax mismatch.

Where an accounting period straddles 1 January 2017, it is split into two notional periods with profits and losses allocated between the two on a just and reasonable basis2. These rules were introduced to address the OECD's BEPS action plan on international corporate tax avoidance.

Prior to IP completion day (ie 11pm on 31 December 2020), the UK was also subject to EU standards on

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