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United Kingdom Tax Agency Seeks Comments on Amendments to Hybrid Mismatch Rules

May 24, 2022, 5:00 AM

The United Kingdom HM Revenue and Customs May 19 opened a consultation on a draft regulation to amend the hybrid and other mismatches rules implemented under the EU Anti-Avoidance Directives (ATAD). Topics covered include: 1) the exemption for specified hybrid capital and debt instruments issued by banks to their overseas associates; and 2) the removal of sunset clause, allowing the exemption to continue to apply from Jan. 1, 2023. Comments are due June 30. [United Kingdom, Government Portal, 05/19/22]

Reference:
View Announcement. View Draft Hybrid and Other Mismatches (Financial Instruments: Excluded Instruments) (Amendment) Regulations 2022. View Explanatory Memorandum ...