Commentary

D4.740 Introduction to tax arbitrage

Corporate tax
Corporate tax | Commentary

D4.740 Introduction to tax arbitrage

Corporate tax | Commentary

Tax arbitrage

D4.740 Introduction to tax arbitrage

The provisions in this article were repealed from 1 January 2017. From 1 January 2017, the rules dealing with hybrid and other mismatches apply; see D4.701 onwards. The latter rules were introduced as part of the OECD BEPS action plan on international corporate tax avoidance.

Anti-avoidance legislation1 aims to deter the use of hybrid entities or instruments (known as tax arbitrage) by companies seeking to exploit differences between or within national tax codes. The legislation operates by reducing or disallowing deductions or by bringing receipts into charge, but applies only where HMRC

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial