UK Tax Focus

Hybrid Mismatches – Advanced Topics

Hybrid Mismatches – Advanced Topics

13 June 2017, 12.00 BST/13.00 CEST
Host: Jim Charlton
Presenters: Adam Powell, Kate Ramm

An updated version of HMRC’s draft hybrids guidance was released in March 2017, but there are still a number of areas of uncertainty and complexity, including key areas that continue to prove problematic from the perspective of both financing and supply chain arrangements.

We'll discuss:

  • The complex computational requirements if a UK disallowance is to be avoided by virtue of sufficient ‘dual inclusion income’ arising, including worked examples.
  • How the measure of dual inclusion changes for US groups by virtue of the mechanics of the US consolidated grouping rules (and / or the US partnership provisions).
  • An update on various options for Financing companies.
  • The revised HMRC guidance in relation to US (or other) state taxes.
  • Areas of uncertainty in relation to the imported mismatch provisions in Chapter 11.
  • The potential impact of the EU’s Anti-Tax Avoidance Directive on arrangements form 1 January 2019 in certain cases.

Find out more about these changes.

Register for this webcast