Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion income under the UK hybrid provisions following a prolonged period of iterative change.
The UK hybrid mismatch provisions (‘the provisions’) have been effective since 1 January 2017. Each Chapter in TIOPA 2010 Part 6A provides a series of prescriptive requirements which counteract specific mismatch arrangements set out in the OECD BEPS Action 2 Report including the supplementary report on permanent establishments (PEs). Notwithstanding the broad description of the underlying policy objectives in the Action 2 Report and its associated examples the UK provisions are regarded by HMRC and most practitioners as being mechanical in nature notably without a purpose-based test commonly seen in UK anti-avoidance legislation...
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Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion income under the UK hybrid provisions following a prolonged period of iterative change.
The UK hybrid mismatch provisions (‘the provisions’) have been effective since 1 January 2017. Each Chapter in TIOPA 2010 Part 6A provides a series of prescriptive requirements which counteract specific mismatch arrangements set out in the OECD BEPS Action 2 Report including the supplementary report on permanent establishments (PEs). Notwithstanding the broad description of the underlying policy objectives in the Action 2 Report and its associated examples the UK provisions are regarded by HMRC and most practitioners as being mechanical in nature notably without a purpose-based test commonly seen in UK anti-avoidance legislation...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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