FA20: Anti-hybrid guidance

Mar 29, 2021

Amendments made by Finance Act 2020 to how the anti-hybrid rules apply to worldwide systems of taxation are now reflected in Tax and Duty Manual Part 35C-00-01. The guidance on anti-hybrid rules have also been updated to include key terms used in the rules, such as “payee”, “reasonable to consider” and associated enterprise”. The “imported mismatch” rule is also included in the guidance. See e-Brief No. 068/21 for further details.