Hybrid mismatch arrangement
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 introduced anti-hybrid tax rules, effective from 2017.
- Base erosion and profit shifting
- CbC reporting
- Common Consolidated Corporate Tax Base
- Corporation Tax
- Diverted profits tax
- Double taxation
- Fixed ratio method
- Hybrid entity
- Multinational corporation/company
- Tax avoidance
- Transfer pricing
- Worldwide interest cap