Hybrid mismatch arrangement: Difference between revisions
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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 (Added link) |
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* [[G20]] | * [[G20]] | ||
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* [[Multinational corporation/company]] | * [[Multinational corporation/company]] | ||
* [[OECD]] | * [[OECD]] | ||
Revision as of 13:33, 12 October 2016
Tax.
A hybrid mismatch arrangement is an arrangement:
- 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.
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.
See also
- Base erosion and profit shifting
- CbC reporting
- Common Consolidated Corporate Tax Base
- Corporation Tax
- Diverted profits tax
- Fixed-ratio method
- G20
- Hybrid
- Hybrid entity
- Multinational corporation/company
- OECD
- Worldwide interest cap
- Tax avoidance
- Transfer pricing
- Double taxation
