United Kingdom Tax Agency Seeks Comments on Taxation of Individual Members of Reverse Hybrid Entities

The United Kingdom HM Revenue and Customs June 10 opened a consultation on proposed amendments on the taxation of resident members of reverse hybrid entities. The proposed amendments include measures to: 1) automatically tax the income of qualifying foreign entities in accordance with the entity’s tax treatment in the relevant foreign jurisdiction; 2) clarify that the amendments would apply to opaque entities treated as transparent entities in the jurisdiction of establishment, and would be limited to the nonresident holdings without a permanent establishment (PE) in the U.K.; 3) treat resident individual members as partners carrying out the entity’s trade or ...