Finance Bill 2021 has now been published and it includes several legislative updates to the anti-hybrid rules following HMRCs recent consultation. This article provides a high level summary of these updates. As you will note, a number of these changes are retroactive and apply from 1 January 2017. There are also provisions which allow taxpayers to apply certain changes to the dual inclusion income rules from 1 January 2017, in spite of accounting periods being closed. This election must be made by 31 December 2021. It will therefore be important to review the positions taken in prior year returns/accounts, to see if any adjustments may be required.
Should you wish to discuss the impact of any of these changes on your business, please speak to your usual PwC contact.