The long and eagerly awaited draft guidance relating to the Hybrids and Other Mismatches legislation (which takes effect from 1 January 2017) has been issued and can be found here: Hybrids and Other Mismatches - draft guidance.
Our specialists will be considering this in detail. To ensure you're aware of the latest thinking and developments on how the rules operate please contact Neil Edwards, Jonathan Hare, Roz Burke or your usual International and Treasury Tax specialist.