Anti-hybrid rules: An overview

Anti-hybrid rules: An overview

On 9 December 2015, the UK published proposed domestic rules to implement the final recommendations made under Action 2 (neutralising the effects of hybrid mismatch arrangements) of the OECD’s base erosion and profit shifting (“BEPS”) project.

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M&A Matters: Anti-hybrid rules - An overview

The new anti-hybrid rules, which broadly follow the OECD’s recommendations, are aimed at counteracting perceived aggressive tax avoidance through arrangements involving hybrid instruments or entities which result in a tax deduction for a payment with no corresponding inclusion in ordinary income, or a double deduction for the same payment.

The new rules apply in four broad scenarios, for further insight read the article in full in the M&A Matters Spring edition PDF

For more information, please contact: 

Michael Bird

Director, KPMG in the UK

John Addison

Manager, KPMG in the UK

Rebecca Davies-Cooke

Assistant Manager, KPMG in the UK

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