Hybrid mismatch arrangement and Netting centre: Difference between pages

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imported>Doug Williamson
(Create the page. Source: Mazars http://blogs.mazars.com/letstalktax/2016/01/hmrc-issues-examples-of-hybrid-mismatch-rules/)
 
imported>Doug Williamson
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''Tax''.
An essential part of a multilateral netting system.


A hybrid mismatch arrangement is an arrangement:
The netting centre acts as a counterparty to all of the participants in the multilateral netting system.
*Intended to secure a tax advantage within a multinational group
*Resulting from a difference in tax treatment of the same financial instrument or entity between different jurisdictions.


Hybrid mismatch arrangements can arise both from hybrid financial instruments and from hybrid entities.
In a group of companies, the netting centre is usually operated by the central or regional treasury centre.




Following OECD and G20 initiatives in relation to tax base erosion and profit shifting, the UK has introduced anti-hybrid tax rules, effective from 2017.
The netting centre typically handles all foreign exchange exposures as well as foreign exchange trading.




==See also==
== See also ==
* [[Base erosion and profit shifting]]
* [[Counterparty]]
* [[CbC reporting]]
* [[Multilateral netting]]
* [[Common Consolidated Corporate Tax Base]]
* [[Multilateral net settlement system]]
* [[Corporation Tax]]
* [[Netting]]
* [[Diverted profits tax]]
* [[Payments and payment systems]]
* [[Fixed-ratio method]]
* [[G20]]
* [[Hybrid]]
* [[Multinational corporation/company]]
* [[OECD]]
* [[Worldwide interest cap]]
* [[Tax avoidance]]
* [[Transfer pricing]]
* [[Double taxation]]
 
 
===Other links===
 
*[[Media:BEPS_report_2013.pdf|OECD Action Plan on Base Erosion and Profit Shifting 2013]]
*[[Media:2015_10_Oct_-_Walk_the_line.pdf| Walk the line, The Treasurer, 2015]]

Revision as of 08:16, 24 May 2015

An essential part of a multilateral netting system.

The netting centre acts as a counterparty to all of the participants in the multilateral netting system.

In a group of companies, the netting centre is usually operated by the central or regional treasury centre.


The netting centre typically handles all foreign exchange exposures as well as foreign exchange trading.


See also

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