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Hybrid and other mismatches - draft guidance
We are seeking comments on this draft guidance on the hybrids mismatch legislation.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This draft guidance is provided to assist understanding of the application of the hybrids mismatch legislation, which take effect from 1 January 2017.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.
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