Two amendments have been made to the hybrid mismatch rules to improve the way these rules will work.
Who should read this?
Multinational groups with a UK parent or UK subsidiaries which have arrangements involving a mismatch in tax treatment, whether between the UK and another jurisdiction or between two non-UK jurisdictions as part of an arrangement involving the UK.
Summary of proposal
The UK Government have made technical amendments to the hybrid and other mismatch rules (Part 6A TIOPA 2010) in two areas.
The changes will apply from the commencement of new hybrid mismatch rules which are effective from 1 January 2017.
Removing the need to make permitted period claims should remove a substantial administrative burden from UK companies which are a party to arrangements involving financial instruments and hybrid transfers, in particular those operating in the financial services sector.
Explicitly excluding amortisation deductions from the scope of the relevant deduction/non-inclusion mismatch chapters aligns the UK rules to the OECD recommendations and to our expectations of how the rules were intended to operate.
KPMG has launched a state of the art digital platform that enhances your experience and provides improved access to our content and our people, whatever device you are on.