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.
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:
Director, KPMG in the UK
Manager, KPMG in the UK
Assistant Manager, KPMG in the UK