Hybrid and other mismatches
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 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