Hybrid mismatch arrangement

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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.

See also

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