CONSULT.Outcome publishedConsultation · gov.uk

Hybrid and other mismatches - draft guidance

We are seeking comments on this draft guidance on the hybrids mismatch legislation.

Last fetched 03 May 2026 · gov.uk

Detail

This draft guidance is provided to assist understanding of the application of the hybrids mismatch legislation, which take effect from 1 January 2017.

The examples contained are based upon a selection of those contained within the OECD ‘Final Report on Neutralising the Effects of Hybrid Mismatch Arrangements’, with additional draft examples dealing with hybrid transfers and permanent establishments.

Documents

Hybrid and Other Mismatches - draft guidance for consultationapplication/pdf Hybrid and Other Mismatches - summary of substantive changes to guidance resulting from consultation responsesapplication/pdf Hybrid and Other Mismatches - updated draft guidance (March 2017)application/pdf