HYBRID-MISMATCHES

Dan Neidle

Jemma Dick

The definition of ‘related’ in the hybrid rules is extremely broad. Dan Neidle and Jemma Dick (Clifford Chance) explain how this could potentially cause companies to be denied interest deductions on ordinary commercial loans.

Kashif Javed

Greg Smythe

Kashif Javed and Greg Smythe (KPMG) review recent developments to HMRC’s draft guidance on the hybrid mismatch rules.

Jeanette Zaman

Zoe Andrews

Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.

Emma Game

Dominic Robertson

Emma Game and Dominic Robertson (Slaughter and May) consider the principal tax issues that can arise when establishing, operating and unwinding a corporate joint venture.

James Ross

James Ross (McDermott Will & Emery) responds to a reader’s different interpretation of the new hybrid rules.

James Ross

James Ross (McDermott Will & Emery) reviews recent developments to the hybrid mismatch rules and HMRC’s draft guidance.

Zoe Wyatt

Tom Wesel

Tom Wesel and Zoe Wyatt (Milestone International Tax Partners) review the revised EC’s Anti-Tax Avoidance Directive which will soon be adopted by the European Parliament to ensure a consistent and uniform implementation of BEPS recommendations across the EU.

James Ross

The Finance Bill hybrid mismatch legislation significantly expands the scope of the December draft legislation. James Ross (McDermott Will & Emery) reviews the changes.

Jeanette Zaman

Jeanette Zaman (Slaughter and May) considers the draft legislation on hybrid mismatch arrangements and discusses their application to commercial transactions and the potential significance of the imported mismatch rules.