Commentary

D4.705 Targeted deduction/non-inclusion arrangements

Corporate tax
Corporate tax | Commentary

D4.705 Targeted deduction/non-inclusion arrangements

Corporate tax | Commentary

Hybrid and other mismatches—deduction/non-inclusion outcomes

D4.705 Targeted deduction/non-inclusion arrangements

The following 'deduction/non-inclusion' arrangements are targeted by the legislation:

  1.  

    (a)     hybrid deduction/non-inclusion arrangements (D4.706) in relation to:

    1.  

      (1)     hybrid financial instruments — where mismatches occur which may be attributable to the terms or features of a financial instrument, for example, if the instrument is treated as debt in one territory and equity in another

    2.  

      (2)     hybrid transfers — repo, stock lending arrangements etc that relate to the transfer of a financial instrument where mismatches may result from the differing ways that parties to arrangements treat them for tax purposes

    3.  

      (3)    

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