Consultation outcome

Hybrid and other mismatches

• From: HM Revenue & Customs
• Published: 19 March 2020
• Last updated: 12 November 2020 — See all updates

This consultation has concluded

Read the full outcome

Hybrid and other mismatches: summary of responses

PDF, 255 KB, 24 pages

Detail of outcome

We received 21 written responses, mainly from advisory firms, representative bodies and businesses affected by the rules.

The government is proposing several changes and clarifications to make the rules more proportionate and to ensure that they apply as intended. We are also proposing a new rule about dual inclusion income to minimise double taxation in certain circumstances.

We have also published draft legislation, an explanatory note and a tax information and impact note (TIIN).

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Original consultation

Summary

We welcome views on the technical application and impact of the double deduction and acting together rules to ensure that both operate proportionately, as intended.

This consultation ran from
8am on 19 March 2020 to 11:45pm on 29 August 2020

Consultation description

This consultation was published on 19 March and was due to close on 29 May. We are grateful for the responses we have already received. The government recognises that many sectors with an interest in this policy are affected by COVID-19. We want to give all stakeholders time to submit their views, so we have extended the consultation. The closing date is now 29 August 2020 (11.45pm). However, we encourage early responses from stakeholders, where possible, to support our ongoing consideration of this policy.

The consultation considers the application of the hybrid and other mismatches legislation regarding:

• double deduction rules in chapters 9 and 10, along with the application of section 259ID income
• acting together definition in chapter 14
• application in respect of exempt investors in hybrid entities

You can read the consultation document on this page, and you can also read:

• current legislation at Part 6A Tax (International Provisions and Other) Act 2010
• HMRC published guidance in the International Manual at INTM850000

Documents

Hybrid and other mismatches - consultation document

PDF, 351 KB, 21 pages

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Published 19 March 2020
Last updated 12 November 2020 + show all updates

1. 12 November 2020

   Published summary of responses and the outcome summary, which includes link to draft legislation, an explanatory note and a tax information and impact note (TIIN).

2. 28 April 2020

   The closing date for responses to the consultation has been extended until 29 August 2020 (11.45pm).

3. 19 March 2020

   First published.